SOVEREIGN INDUSTRIAL GROUP Limited
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Sovereign Industrial Group Limited

Privacy Policy

Version 1.0 Effective: May 2025 Next Review: May 2026

Sovereign Industrial Group Limited ("SIGL", "we", "us", "our") is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. Please read it carefully.

Registered Office: Sovereign Industrial Group Limited, Leofric House, 18b Binley Road, Coventry CV3 1JN, United Kingdom. We are a data controller registered under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Data We Collect

We may collect and process the following personal data:

  • Identity Data: name, job title, company name
  • Contact Data: email address, telephone numbers, postal address
  • Technical Data: IP address, browser type and version, time-zone, operating system
  • Usage Data: information about how you use our website and services
  • Communications Data: records of correspondence with us
  • Professional Data: information provided in connection with procurement, supply chain, investor or employment enquiries

2. How We Use Your Data

We use personal data for the following purposes and on the following lawful bases:

  • To respond to enquiries and manage business relationships — Legitimate interests / Contract
  • To provide information about our products, services, and investment activities — Legitimate interests / Consent
  • To comply with legal and regulatory obligations — Legal obligation
  • To maintain the security of our systems — Legitimate interests
  • To analyse website usage and improve our digital presence — Legitimate interests

3. Data Sharing

We do not sell your personal data. We may share it with:

  • Professional advisers (solicitors, accountants, auditors) bound by duties of confidentiality
  • IT service providers and data processors acting on our instructions
  • Regulatory bodies, law enforcement, or courts where required by law
  • Successor entities in the event of a corporate transaction involving SIGL

4. International Transfers

Where we transfer personal data outside the UK, we ensure appropriate safeguards are in place in accordance with UK GDPR requirements, including the use of International Data Transfer Agreements (IDTAs) or adequacy decisions where applicable.

5. Data Retention

We retain personal data only for as long as necessary for the purposes set out in this policy and to satisfy our legal obligations. Business contact records are ordinarily retained for six years from the date of last contact; financial and contractual records are retained for seven years in line with HMRC requirements.

6. Your Rights

Under UK GDPR you have the right to:

  • Access your personal data
  • Rectification of inaccurate data
  • Erasure ("right to be forgotten") in certain circumstances
  • Restriction of processing
  • Data portability
  • Object to processing based on legitimate interests
  • Withdraw consent at any time where processing is consent-based

To exercise any of these rights, please contact our Data Protection contact below. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

7. Cookies

Our website uses cookies. Please see our Cookie Policy for full details.

8. Changes to This Policy

We may update this policy from time to time. Any changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically.

Data Protection Contact Sovereign Industrial Group Limited
Email: privacy@sovereignindustrialgroup.com
For urgent data protection concerns please mark correspondence: FAO Data Protection
Sovereign Industrial Group Limited

Cookie Policy

Version 1.0 Effective: May 2025 Next Review: May 2026

This Cookie Policy explains what cookies are, how Sovereign Industrial Group Limited uses them on our websites, and how you can manage your preferences.

1. What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They are widely used to make websites work efficiently, to provide analytics information to site owners, and to remember your preferences.

2. Types of Cookies We Use

Strictly Necessary Cookies

These cookies are essential for our website to function and cannot be disabled. They include session management and security tokens. No consent is required for these cookies.

Performance & Analytics Cookies

These cookies collect information about how visitors use our site, such as which pages are visited most often and whether error messages are received from web pages. All data collected is aggregated and anonymous. We use these cookies only with your consent.

Functionality Cookies

These cookies allow our website to remember choices you have made (such as language preferences) to provide enhanced and more personalised features. We use these cookies only with your consent.

Marketing Cookies

We do not currently use marketing or advertising cookies on our website.

3. Third-Party Cookies

Our website may include content or functionality from third-party providers (such as embedded maps or video content) which may set their own cookies. We do not control these cookies and recommend you review the privacy policies of the relevant third parties.

4. Managing Your Cookie Preferences

You can manage your cookie preferences at any time using our Cookie Preference Centre. You may also control cookies through your browser settings, though disabling certain cookies may affect the functionality of our website. Most browsers allow you to:

  • View the cookies stored on your device
  • Delete individual or all cookies
  • Block cookies from specific websites
  • Block all cookies from all websites

For further information on managing cookies in your specific browser, visit allaboutcookies.org or your browser's help documentation.

5. Changes to This Policy

We may update this Cookie Policy from time to time as our cookie usage changes or as required by law. Please review this page periodically.

Sovereign Industrial Group Limited

Terms of Use

Version 1.0 Effective: May 2025 Next Review: May 2026

These Terms of Use govern your use of the websites operated by Sovereign Industrial Group Limited ("SIGL"). By accessing our websites you agree to be bound by these terms. If you do not agree, please do not use our websites.

1. Information on This Website

The content on this website is provided for general information purposes only. It does not constitute legal, financial, investment, or professional advice of any kind. While we take reasonable care to ensure accuracy, we make no warranties or representations regarding the completeness, accuracy, or fitness for purpose of any information published.

2. Intellectual Property

All content on this website — including text, graphics, logos, images, and software — is the property of Sovereign Industrial Group Limited or its licensors and is protected by copyright and other intellectual property laws. You may:

  • Print or download content for personal, non-commercial use
  • Share content with third parties for informational purposes, provided attribution is given

You may not reproduce, modify, or commercially exploit any content without our prior written consent.

3. Prohibited Uses

You must not use our websites:

  • In any unlawful manner or for any unlawful purpose
  • To transmit unsolicited commercial communications
  • To attempt to gain unauthorised access to our systems or networks
  • In any way that could damage, disable, overburden, or impair our infrastructure
  • To introduce viruses, trojans, worms, logic bombs, or other malicious material

4. Third-Party Links

Our websites may contain links to external websites operated by third parties. We do not endorse and have no control over the content of those websites. We accept no responsibility for any loss or damage arising from your use of them.

5. Limitation of Liability

To the fullest extent permitted by law, SIGL excludes all liability for any direct, indirect, or consequential loss arising from your use of our websites or inability to use them, including reliance on any information published on our websites. Nothing in these terms excludes liability for fraud, death, or personal injury caused by negligence.

6. Governing Law

These Terms of Use are governed by the laws of England and Wales. Any disputes arising in connection with these terms shall be subject to the exclusive jurisdiction of the courts of England and Wales.

7. Changes to These Terms

We may amend these Terms of Use at any time. Continued use of our websites following any change constitutes acceptance of the revised terms.

Sovereign Industrial Group Limited

Accessibility Statement

Version 1.0 Effective: May 2025 Next Review: May 2026

Sovereign Industrial Group Limited is committed to making its websites accessible to all users, including those with disabilities. This statement applies to all websites operated under the SIGL group umbrella.

1. Our Commitment

We aim to achieve compliance with the Web Content Accessibility Guidelines (WCAG) 2.1 at Level AA. We continually review our websites to identify and remedy accessibility barriers.

2. Technical Specification

Our websites rely on the following technologies for conformance:

  • HTML5
  • CSS3
  • JavaScript (ES6+)

3. Known Limitations

Where we are aware of content that does not fully meet the WCAG 2.1 AA standard, we are actively working to address this. If you encounter any accessibility issue not described here, please contact us using the details below.

4. What We Are Doing

  • Using semantic HTML to aid screen reader navigation
  • Providing text alternatives for non-text content
  • Ensuring sufficient colour contrast between foreground and background content
  • Designing for keyboard navigability throughout
  • Avoiding content that flashes more than three times per second
  • Providing meaningful link text and descriptive page titles

5. Feedback & Contact

If you experience any difficulty accessing content on our websites, or wish to request an alternative format, please contact us:

Accessibility Contact Sovereign Industrial Group Limited
Email: accessibility@sovereignindustrialgroup.com
We aim to respond to accessibility feedback within five business days.

6. Enforcement

If you are not satisfied with our response, the Equality and Human Rights Commission (EHRC) is the enforcement body for the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 in England, Scotland, and Wales. You may also contact the Equality Advisory and Support Service (EASS).

Sovereign Industrial Group Limited

Modern Slavery & Human Trafficking Statement

Financial Year 2024–25 Published: May 2025 Approved by the Board of Directors

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps taken by Sovereign Industrial Group Limited ("SIGL") to ensure that modern slavery and human trafficking are not present in our business or supply chains.

1. Our Business

SIGL is a UK-incorporated holding company operating as an advanced manufacturing buy-and-build group, with operations and supply chain relationships spanning the automotive and aerospace sectors. Our subsidiaries operate across England, supplying tier-one and tier-two components to major original equipment manufacturers.

2. Our Policies

We operate a number of internal policies relevant to modern slavery risk, including:

  • Our Supplier Code of Conduct, which sets out our expectations of ethical behaviour throughout the supply chain
  • Our Whistleblowing Policy, which enables employees and third parties to report concerns confidentially
  • Our Recruitment Policy, which requires all hiring to be conducted through reputable channels with right-to-work checks
  • This Modern Slavery Statement

3. Due Diligence

We conduct due diligence on our supply chain to assess and address modern slavery risk. This includes:

  • Risk assessments of new and existing suppliers, with enhanced scrutiny applied to higher-risk geographies and sectors
  • Supplier questionnaires covering labour practices, working conditions, and modern slavery compliance
  • Contractual provisions requiring suppliers to comply with applicable laws, including modern slavery legislation
  • Ongoing monitoring and periodic supplier reviews

4. Risk Assessment

We have assessed that the principal modern slavery risks within our operations are low, given that our workforce is predominantly UK-based and engaged through direct employment. We remain vigilant, particularly in relation to sub-tier supply chains in regions with higher prevalence of labour exploitation.

5. Training & Awareness

We provide awareness training to employees whose roles involve supply chain management and procurement. All new employees receive onboarding information relating to our ethical standards and how to report concerns.

6. Key Performance Indicators

We will measure the effectiveness of our actions through:

  • Completion rates of modern slavery training by relevant staff
  • Number of suppliers assessed against our Supplier Code of Conduct
  • Number and outcome of concerns raised through our Whistleblowing Policy

This statement has been approved by the Board of Directors of Sovereign Industrial Group Limited and is reviewed annually. It is signed on behalf of the Board by the Executive Chairman.

Signed David Roberts — Executive Chairman
Sovereign Industrial Group Limited
May 2025
Sovereign Industrial Group Limited

Anti-Bribery & Corruption Policy

Version 1.0 Effective: May 2025 Next Review: May 2026 Approved by the Board

Sovereign Industrial Group Limited ("SIGL") has a zero-tolerance approach to bribery and corruption. This policy is made under the Bribery Act 2010 and applies to all persons associated with SIGL, including directors, employees, agents, subsidiaries, and business partners.

1. Policy Statement

We are committed to acting with integrity and professionalism in all our business dealings and relationships, wherever we operate. We will uphold all laws relevant to countering bribery and corruption.

Zero Tolerance: SIGL will not tolerate bribery or corruption in any form. Any breach of this policy will be treated as gross misconduct and may result in dismissal, termination of commercial relationships, and referral to the relevant authorities.

2. Scope

This policy applies to:

  • All employees (permanent, temporary, and contract) of SIGL and its subsidiaries
  • All directors and officers
  • All agents, consultants, joint venture partners, and third parties acting on SIGL's behalf

3. What Is Prohibited

The following are strictly prohibited:

  • Offering, promising, giving, requesting, or accepting a bribe or facilitation payment
  • Providing gifts, hospitality, or entertainment to or from a public official or business contact for the purpose of gaining or retaining a business advantage
  • Using a third party to channel a bribe on SIGL's behalf
  • Making or receiving payments or advantages in connection with public procurement

4. Gifts & Hospitality

Proportionate and reasonable gifts and hospitality are permitted where they are:

  • Consistent with normal business courtesies in the relevant sector
  • Not made to or received from public officials unless specifically approved
  • Recorded in our Gifts & Hospitality Register
  • Below the thresholds established in our internal Gifts & Hospitality Procedure

5. Due Diligence

We conduct proportionate due diligence on third parties acting on our behalf, particularly agents and intermediaries operating in higher-risk jurisdictions. Contractual provisions requiring compliance with applicable anti-bribery laws are incorporated into relevant agreements.

6. Reporting Concerns

Any person subject to this policy who suspects a breach or has concerns should report this immediately to the Executive Chairman or through our Whistleblowing channel. Reports will be treated in confidence. Retaliation against anyone raising a genuine concern in good faith will not be tolerated.

7. Training

All employees in roles carrying material bribery risk receive appropriate training on this policy. Training records are maintained and reviewed annually.

Policy Owner David Roberts — Executive Chairman
Sovereign Industrial Group Limited
For concerns: compliance@sovereignindustrialgroup.com
Sovereign Industrial Group Limited

Quality Policy

Version 1.0 Effective: May 2025 Next Review: May 2026 Approved by the Board

Sovereign Industrial Group Limited and its subsidiaries are committed to delivering products and services that consistently meet or exceed customer, statutory, and regulatory requirements. Quality is a fundamental value embedded in everything we do.

1. Our Quality Commitment

We are committed to:

  • Understanding and fulfilling the needs and expectations of our customers across the automotive and aerospace sectors
  • Delivering right-first-time quality, targeting zero-defect performance across all operations
  • Maintaining and continually improving our Quality Management Systems in alignment with ISO 9001:2015 and, where applicable, IATF 16949:2016 and AS9100 Rev D
  • Meeting applicable legal, statutory, and regulatory requirements
  • Providing the resources, infrastructure, and training necessary to support quality objectives
  • Embedding a culture of continuous improvement throughout the organisation

2. Quality Management Framework

Our quality management approach is founded on:

  • Customer Focus: Proactively monitoring customer satisfaction and acting on feedback
  • Process Approach: Managing activities as interrelated processes to achieve consistent and predictable results
  • Evidence-Based Decisions: Using data and performance metrics to drive improvement actions
  • Leadership Accountability: Ensuring quality ownership at every level of the organisation, from the Board downward
  • Supplier Quality: Holding our supply chain to the same quality standards we set for ourselves

3. Objectives & Measurement

Specific, measurable quality objectives are set annually by Group management and reviewed at quarterly management reviews. These objectives are communicated throughout the organisation and aligned to our strategic priorities.

Our automotive operations target quality performance benchmarked against Six Sigma standards. Continuous improvement is tracked via structured lean methodologies and regular management review.

4. Responsibility

Every employee of SIGL and its subsidiaries has a personal responsibility to uphold our quality standards and to raise concerns where quality may be compromised. The Group Quality Director has overall accountability for the Quality Management System.

Policy Owner David Roberts — Executive Chairman
Sovereign Industrial Group Limited
quality@sovereignindustrialgroup.com
Sovereign Industrial Group Limited

Environmental Policy

Version 1.0 Effective: May 2025 Next Review: May 2026 Approved by the Board

Sovereign Industrial Group Limited recognises that our operations have an impact on the natural environment. We are committed to managing that impact responsibly and to operating sustainably across all our sites and supply chain activities.

1. Our Environmental Commitment

We commit to:

  • Complying with all applicable environmental legislation, regulations, and permit conditions
  • Minimising waste generated by our operations and maximising recycling and reuse
  • Reducing energy consumption and carbon emissions across our sites
  • Preventing pollution and protecting the local environment around our facilities
  • Procuring materials and services from suppliers who share our environmental values
  • Continually improving our environmental performance through objective-setting and regular review

2. Energy & Emissions

SIGL is actively investing in renewable energy and energy efficiency measures across its operational footprint. We monitor energy consumption and carbon emissions data and report against reduction targets set by Group management. Our operations include renewable electricity supply arrangements, and we are committed to further decarbonisation as our group grows.

3. Waste Management

We apply a hierarchy of waste prevention, reuse, recycling, and responsible disposal. Hazardous waste arising from our manufacturing operations is handled by licensed contractors in accordance with the Environmental Protection Act 1990 and the Hazardous Waste Regulations 2005.

4. Supply Chain

We include environmental performance expectations in our Supplier Code of Conduct and take environmental compliance into account when selecting and retaining suppliers.

5. Environmental Management System

We work towards alignment with ISO 14001:2015 across our operational sites. Environmental objectives are set annually and reviewed at management review meetings. Progress is communicated to employees and relevant stakeholders.

6. Responsibility

Environmental responsibility is shared by all employees. Managers are accountable for environmental performance within their areas of responsibility. The Board of Directors holds ultimate accountability for this policy and our overall environmental performance.

Policy Owner David Roberts — Executive Chairman
Sovereign Industrial Group Limited
environment@sovereignindustrialgroup.com
Sovereign Industrial Group Limited

Whistleblowing Policy

Version 1.0 Effective: May 2025 Next Review: May 2026 Approved by the Board

Sovereign Industrial Group Limited is committed to the highest standards of conduct and integrity. This Whistleblowing Policy enables employees, contractors, suppliers, and other stakeholders to raise concerns about wrongdoing, without fear of retaliation. It is made in accordance with the Public Interest Disclosure Act 1998 (PIDA) as amended.

1. Purpose

This policy encourages anyone associated with SIGL to speak up when they have reasonable grounds to believe that:

  • A criminal offence has been, is being, or is likely to be committed
  • A legal obligation has been or is being breached
  • There is a risk to health and safety of any individual
  • The environment is being or is likely to be damaged
  • A miscarriage of justice has occurred or is likely to occur
  • Information relating to any of the above is being, or is likely to be, concealed
  • There has been or is likely to be a breach of our Anti-Bribery, Modern Slavery, or other Group policies

This policy is not a mechanism for raising personal grievances. Personal employment or workplace disputes should be addressed through our Grievance Procedure. However, a concern need not be proven — it is sufficient for a disclosure to be made in good faith.

2. How to Raise a Concern

Concerns may be raised through any of the following channels:

  • Directly to the Executive Chairman: david.roberts@sovereignindustrialgroup.com
  • Confidential email: whistleblowing@sovereignindustrialgroup.com
  • In writing: Marked Private & Confidential, addressed to the Executive Chairman at Sovereign Industrial Group Limited, Leofric House, 18b Binley Road, Coventry CV3 1JN, United Kingdom
  • Anonymous reporting: We accept anonymous concerns. Please be aware that anonymous reports may be more difficult to investigate fully.

3. Confidentiality

We will make every effort to protect the identity of any person who raises a concern, subject to legal obligations. Information provided will be disclosed only to those who need to know it to investigate or resolve the matter.

4. Protection from Retaliation

SIGL will not tolerate any detrimental treatment of anyone who raises a concern in good faith under this policy. This includes dismissal, demotion, harassment, or any other form of retaliation. Any employee who subjects another to detrimental treatment for having raised a concern will face disciplinary action, up to and including dismissal.

5. Investigation

All concerns will be assessed and, where appropriate, investigated promptly and fairly. The person raising the concern will ordinarily be informed of the outcome of any investigation, subject to the need to preserve the confidentiality of others involved. SIGL will not make findings of fact regarding matters that are the proper province of the courts.

6. External Reporting

Nothing in this policy prevents a person from making a protected disclosure directly to a prescribed regulator or other external body, including:

  • The Financial Conduct Authority (FCA)
  • The Health and Safety Executive (HSE)
  • The Environment Agency
  • The Serious Fraud Office (SFO)
  • Protect (formerly Public Concern at Work), the whistleblowing charity — protect-advice.org.uk

7. Record-Keeping

Records of all concerns raised under this policy and their outcomes are maintained securely and confidentially. These records are reviewed periodically by the Board as part of our governance oversight.

Whistleblowing Contact Sovereign Industrial Group Limited
Confidential email: whistleblowing@sovereignindustrialgroup.com
All communications treated in strict confidence.