ANTI SLAVERY LEGISLATION

1 MODERN SLAVERY STATEMENT

JML SLAVERY AND HUMAN TRAFFICKING STATEMENT 2026

1. Introduction

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps that JML has taken during the financial year ending April 2026 to prevent modern slavery and human trafficking in our business operations and supply chains.
JML is a UK-based omni-channel retailer and consumer product brand, operating through in-store concessions, television shopping, and e-commerce platforms. Our global supply chain is managed by our Product Development team in the UK.
We are committed to conducting business ethically and with integrity, and to implementing effective systems and controls to safeguard against modern slavery.

2. Our Structure, Business and Supply Chains

JML operates primarily in the UK, with manufacturing concentrated in the Far East, particularly China. Our supply chain consists of third-party manufacturers producing consumer goods to JML specifications.
We recognise that the nature of our sourcing model presents inherent risks, particularly in regions where labour standards enforcement may vary. The majority of our exposure to modern slavery risk lies within our manufacturing supply chain.

3. Policies in Relation to Modern Slavery

We maintain a suite of policies designed to prevent modern slavery and promote ethical business conduct, including:

Ethical Sourcing Policy
Supplier Code of Conduct
Corporate Social Responsibility Policy
Whistleblowing Policy

Our Supplier Code of Conduct aligns with the Ethical Trading Initiative (ETI) Base Code and requires:

Employment is freely chosen
Freedom of association and collective bargaining
Safe and hygienic working conditions
No child labour
Payment of living wages
Reasonable working hours
No discrimination
Regular employment
No harsh or inhumane treatment
Transparency in subcontracting
Compliance with environmental regulations

All suppliers are required to formally acknowledge and adhere to these standards.

4. Due Diligence Processes

We apply a risk-based due diligence framework to identify, assess, and mitigate modern slavery risks within our supply chain.

Supplier Onboarding

All new suppliers undergo an approval process led by senior management
Suppliers must disclose all manufacturing sites
Ethical sourcing compliance is a prerequisite for engagement

Auditing and Monitoring

We require independent third-party audits (SMETA, BSCI, WRAP, ICTI) where appropriate
Semi-announced and unannounced site visits are conducted during production
Suppliers are subject to ongoing performance reviews

Corrective Action and Remediation

Where non-compliances are identified, corrective action plans are issued
We work collaboratively with suppliers to address issues
Persistent failure to improve or serious breaches may result in termination of the business relationship

During the reporting period, common audit findings included excessive working hours and documentation gaps. These were addressed through corrective action plans and follow-up assessments.

5. Risk Assessment and Management

We assess modern slavery risk using a structured approach considering:

Geographic risk (e.g. high-risk regions such as parts of the Far East)
Sector and product risk
Nature of the workforce (including use of migrant or temporary labour)
Supplier history and audit performance

Risk assessments are reviewed regularly and inform our audit and engagement strategy. China remains our highest-risk sourcing region due to the concentration of manufacturing activity.

6. Measuring Effectiveness

We monitor the effectiveness of our approach using key performance indicators (KPIs), including:

Percentage of suppliers signed to our Ethical Sourcing Policy
Percentage of suppliers with valid third-party audits
Number of corrective action plans issued and closed

2026 Performance:

34 active suppliers
32 suppliers (94%) signed to the Ethical Sourcing Policy
28 suppliers (82%) with third-party audits (some audits expired during the year)
From the third-party audits no Critical Failure has been identified.

Continuous Improvement Targets:

Achieve 100% supplier sign-up to the Ethical Sourcing Policy
Ensure all suppliers maintain valid, up-to-date audit reports
Reduce recurrence of non-compliance findings year-on-year

7. Grievance Mechanisms and Whistleblowing

We are committed to ensuring that concerns can be raised safely and without fear of retaliation.

Employees are encouraged to report concerns via our Whistleblowing Policy
We ensure protection against detrimental treatment for those who raise concerns in good faith

We also expect our suppliers to provide appropriate grievance mechanisms for their workers, including access to confidential reporting channels.

8. Training and Capacity Building

We provide training to ensure employees understand modern slavery risks and their responsibilities.

Training forms part of the induction process for all relevant employees
Additional training is provided to teams involved in procurement and supply chain management
Refresher training is delivered periodically based on risk and role

We aim to expand training coverage and enhance content in line with evolving best practice.

9. Continuous Improvement

We are committed to continuously improving our approach to tackling modern slavery. During the next financial year, we will:

Enhance supplier risk assessment methodologies
Increase audit coverage and follow-up verification
Expand internal training programmes
Monitor emerging best practices and regulatory developments

10. Board Approval

This statement is approved by the Board of Directors.