Modern Slavery Act Statement

The Modern Slavery Act Statement is presented on behalf of Gordon Brothers Group, LLC and its UK subsidiaries, which fall within the scope of section 54 of the Modern Slavery Act 2015. The Statement sets out the steps which have been taken during the financial year ending December 31, 2025, to prevent modern slavery and human trafficking in our business operations and supply chains.

Gordon Brothers is committed to conducting business ethically and with integrity. We have zero tolerance for modern slavery and human trafficking in any part of our operations or supply chains, and we are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place.

Organization Structure, Business and Supply Chains

Gordon Brothers is a global advisory, restructuring, and investment firm specializing in asset-based lending, financing, and trading. Since 1903, we have maximized liquidity through realizable asset value by providing expertise and capital to solve business challenges across retail, commercial, industrial, brands, and real estate sectors.

Gordon Brothers operates from over 50 offices across North America, Europe, the Middle East, Africa, and Asia Pacific, with our headquarters in Boston, Massachusetts, USA. Our services include:

  • Asset services and valuations
  • Lending and financing solutions
  • Trading and liquidation services
  • Real estate advisory and investment

Our supply chain primarily consists of:

  • Professional services providers (legal, accounting, consulting, technology)
  • Facilities and office management (cleaning, security, maintenance, catering)
  • Technology and telecommunications (software, hardware, data services)
  • Marketing and communications (advertising agencies, printing, events)
  • Travel and logistics (airlines, hotels, ground transportation)

Policies Concerning Modern Slavery and Human Trafficking

Gordon Brothers has implemented the following policies and procedures to address modern slavery risks:

Code of Business Ethics and Conduct

Our Code of Conduct sets clear expectations for all employees, contractors, and business partners regarding ethical behavior, including respect for human rights and prohibition of forced labor. The Code of Conduct is based on our five shared enterprise values, the first of which is Behave with Integrity: doing the right thing, acting responsibly and holding ourselves accountable.

Supplier Conduct

We seek to do business with suppliers that adhere to ethical procurement standards, which prohibit:

  • Use of forced, bonded, or involuntary labor
  • Employment of workers under the minimum legal working age
  • Physical punishment or abuse of workers
  • Withholding of identity documents or restricting freedom of movement

Speak Up Policy

We maintain confidential reporting mechanisms for employees and third parties to report suspected violations, including potential modern slavery issues, without fear of retaliation. Confidential reporting is available through Ethical Advocate at gordonbrothers.ethicaladvocate.com.

Gordon Brothers investigates any reported concerns or red flags.

Training on Modern Slavery and Human Trafficking

Gordon Brothers provides training and awareness programs including:

Employee Training

  • Annual mandatory training on the Code of Conduct for all employees
  • General awareness training for all employees on recognizing signs of modern slavery

Plans for Financial Year 2026

Looking ahead, Gordon Brothers commits to:

  • Establishing KPIs to measure program effectiveness
  • Implementing enhanced due diligence for suppliers in higher-risk categories

In accordance with the UK Modern Slavery Act 2015 and associated guidance, this statement has been duly signed by a Director.