Modern Slavery and Human Trafficking Statement
For the financial year ended 31 December 2025
- Introduction
- Our Business and Supply Chains
- Policies and Standards
- Risk Assessment and Due Diligence
- Training and Awareness
- Effectiveness of Controls
- Future Steps and Continued Commitment
- Approval of this Statement
Introduction
This statement is made by AP Racing Limited for the financial year ended 31 December 2025 pursuant to section 54 of the Modern Slavery Act 2015. It describes the steps AP Racing has taken during the year to help prevent slavery and human trafficking in its business and supply chains.
Modern slavery includes slavery, servitude, forced or compulsory labour and human trafficking. AP Racing has a zero-tolerance approach to modern slavery and is committed to conducting business ethically and with integrity.
Our Business and Supply Chains
AP Racing Limited is a leading manufacturer of performance brake and clutch systems for road and race cars. The business operates from Coventry, United Kingdom and is a wholly owned subsidiary within the Brembo group, whose parent company is Brembo N.V., a listed company.
AP Racing's activities include the design, manufacture and assembly of clutches, calipers, discs, pads, master cylinders, pedal boxes and air jacks, as well as road and competition brake systems for motorcycles.
AP Racing has a global supply chain supporting its manufacturing activities. This includes suppliers in the United Kingdom, Europe and Asia. AP Racing recognises that modern slavery risks may be higher in certain regions, sectors or parts of international supply chains and takes this into account in its supplier management
processes.
Policies and Standards
AP Racing maintains policies and standards designed to support ethical business conduct and responsible employment and supply chain practices. These include:
- an Anti-Slavery and Human Trafficking Policy;
- the Brembo Supplier Code of Conduct, which sets expectations for suppliers, including in relation to human rights, forced labour and compliance with applicable laws;
- a Whistleblowing Policy, which enables concerns to be raised without fear of reprisal;
- human resources procedures covering recruitment, right-to-work checks and employment conditions; and
- relevant purchasing and supplier approval
Suppliers are expected to comply with applicable laws and AP Racing's supplier standards. Where AP Racing becomes aware of conduct that is inconsistent with those standards, it may require remedial action or take other appropriate steps, including ending the supplier relationship where necessary.
Risk Assessment and Due Diligence
AP Racing considers the risk of modern slavery within its directly employed workforce to be low, reflecting its skilled workforce, direct employment arrangements, right-to-work checks and established HR processes.
The principal area of potential risk is within the supply chain, particularly where goods or services are sourced internationally or where AP Racing has less visibility beyond its first-tier suppliers. AP Racing undertakes proportionate supplier due diligence when engaging suppliers and may undertake additional review where the nature of the goods or services, the supplier location, the sector or other information indicates a potentially higher risk.
Due diligence may include supplier onboarding checks, review of publicly available information, confirmation of supplier compliance expectations, review of supplier policies where relevant and follow-up discussions with suppliers where concerns arise.
As part of the wider Brembo Group's supplier compliance framework, suppliers within designated regions and categories may be subject to periodic sustainability, ethical and compliance assessments administered through external specialist providers, including NQC. These assessments may include supplier questionnaires, documentary reviews and, where considered appropriate, independent audits. Supplier populations are reviewed and validated periodically to maintain relevance and coverage. Assessment results are evaluated against defined acceptance criteria and any identified non-conformities or areas requiring improvement are reviewed and managed through established supplier management processes, including the implementation and monitoring of corrective actions where appropriate.
Training and Awareness
AP Racing provides appropriate awareness to relevant employees, including employees involved in purchasing, supplier management and human resources, so that they understand modern slavery risks and know how to raise concerns.
Employees are encouraged to report concerns through line management, Human Resources or the whistleblowing process. AP Racing does not tolerate retaliation against anyone who raises a concern in good faith.
Effectiveness of Controls
AP Racing monitors the effectiveness of its approach through its existing management processes, supplier approval and review arrangements, HR procedures and whistleblowing channels.
AP Racing also benefits from supplier monitoring activities undertaken at Brembo Group level, including the review of supplier assessment outcomes and remediation activities arising from ethical, sustainability and compliance evaluations conducted through the Group's supplier oversight processes.
AP Racing is not aware of any confirmed instances of modern slavery or human trafficking within its business or supply chain during the financial year ended 31 December 2025.
Future Steps and Continued Commitment
AP Racing will continue to review its policies and procedures relating to modern slavery and human trafficking and will continue to work with suppliers and other stakeholders to support responsible business practices within its supply chain.
AP Racing will also continue to align, where appropriate, with relevant Brembo group policies, codes of conduct and compliance expectations.
Approval of this Statement
This statement was approved by the Board of Directors of AP Racing Limited on 30 June 2026 and is signed on its behalf by:
David Hamblin
Managing Director
AP Racing Limited