Modern Slavery Policy

Policy Statement

This Modern Slavery Policy has been published by BB (UK) Ltd. This covers the Company for the financial year ending 31^st December 2023.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, suppliers and manufacturers.

The Company strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery and human trafficking are not taking place within our organisation or in any of our supply chains. We expect that our suppliers and manufacturers will hold their own suppliers to the same high standards, if applicable.

Definitions

Modern Slavery and Human Trafficking

Modern slavery is a term used to encompass slavery, servitude, forced labour, compulsory labour, bonded and child labour and human trafficking. Modern slavery is a crime and a violation of fundamental human rights.

Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited.

Commitments

We as a Company expect that everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery and human trafficking:

1. We have a zero-tolerance approach to modern slavery and human trafficking in our organisation and our supply chains.

2. The prevention, detection and reporting of modern slavery and human trafficking in any part of our organisations or supply chain is the responsibility of all those working for us or on our behalf. Suppliers, manufacturers and workers in our supply chains must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.

3. We are committed to engaging with our stakeholders, suppliers and manufacturers to address the risk of modern slavery in our operations and supply chain.

4. Prior to working with suppliers and manufacturers, we require that each signs a Manufacturing Agreement (“Agreement”) that includes a Code of Conduct and/or Standards of Practice. By signing the Agreement, the suppliers and manufacturers agree:

1. To meet or exceed the standards set by all applicable laws and regulations related to workers’ rights and working conditions, including but not limited to, those laws concerning age, hours of work, minimum wage, overtime, timely payments, and retirement benefits; and

1. Not to employ forced child labour or forced labour of any kind.

5. Beginning in 2021, we added a section to our manufacturing agreements that specifically addresses and prohibits modern slavery and human trafficking. The agreement along with our Codes of Conduct and/or Standards of Practice, attached to each manufacturing agreement, set out the standards required to combat modern slavery and human trafficking.

6. Consistent with our approach, we may require that suppliers and manufacturers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code of Conduct and/or Standards of Practice.

7. If we find that other individuals, organisations, suppliers and manufacturers working on our behalf have breached this policy, we will ensure that we take appropriate action, likely ending the working relationship.

Due Diligence

As part of our due diligence processes, we actively encourage staff, suppliers and any partners in our supply chain to contact us with their concerns or worries about ethical treatment in our supply chain. We also ensure confidentiality and protection from victimization, detrimental treatment of any individual contacting us with their concerns about any part of our business.

We also require that our suppliers and manufacturers undergo official audits and keep their certifications up-to-date. The ethical audits must be successfully repeated annually.

Ongoing Action

This policy and the above commitments are reviewed annually by the Group CEO and the Company’s compliance team. The review includes ensuring the policy remains relevant and effective as well as appraising key partners in the supply chain to ensure they continue to meet our requirements and commitments. The reviewed policy is revised as required.