QP 37

MODERN SLAVERY POLICY

Jaybee Supplies Limited

 

Jaybee Supplies Limited is committed to preventing modern slavery and human trafficking in all its forms. We recognise our responsibility to act ethically and with integrity in all our business dealings and relationships, and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

 

Jaybee Supplies Limited condemns slavery and human trafficking in all its forms and is committed to:

• Complying with all relevant legislation, regulations, and international standards relating to modern slavery.
• Upholding the principles of freedom, dignity, and human rights for all individuals.
• Ensuring that slavery and human trafficking are not taking place in any part of our business or supply chains.
• Taking steps to identify and assess potential risks of modern slavery in our operations and supply chains, and going beyond minimum legal requirements to seek independent, evidence-based assurance from our suppliers.
• Implementing effective measures to prevent, detect, and address any instances of modern slavery.
• Providing training and raising awareness among our employees and stakeholders to recognise and respond to modern slavery risks.
• Collaborating with suppliers, contractors, and other business partners to promote transparency and ethical practices throughout our supply chains, including mapping our supply chain beyond first-tier suppliers.

It is the responsibility of all employees, contractors, and other parties working on behalf of Jaybee Supplies Limited to:

• Familiarise themselves with this Modern Slavery Policy and comply with its provisions.
• Report any concerns or suspicions regarding modern slavery or human trafficking promptly to the designated point of contact.
• Cooperate with any investigations into allegations of modern slavery or human trafficking.

A named senior individual holds board-level accountability for modern slavery compliance within Jaybee Supplies Limited, and is responsible for overseeing the due diligence programme described in this policy.

Jaybee Supplies Limited will conduct regular risk assessments to identify and evaluate the potential risks of modern slavery in its operations and supply chains. This includes:

• Assessing the geographical locations of suppliers and the prevalence of modern slavery in those regions.
• Reviewing the labour practices and working conditions of suppliers and contractors.
• Evaluating the effectiveness of existing controls and monitoring mechanisms.

Due diligence is carried out proportionately, with higher-risk suppliers receiving deeper scrutiny, and is evidenced rather than declaratory. In practice, this means:

• Mapping our supply chain beyond Tier 1 (direct suppliers) to understand, where possible, the Tier 2 and Tier 3 sites — raw materials, fabric mills, and finishing — that sit behind the goods we sell.
• Requiring all new and existing suppliers to complete our Supplier Due Diligence Questionnaire (QP 106) as part of on boarding and periodic review.
• Placing weight on independent, third-party verification — such as Sedex membership with a current SMETA audit, or SA8000/BSCI certification — rather than relying on supplier self-declaration alone.
• Including a supplier code of conduct in our contractual terms, with an explicit right to audit and a right to terminate for breach and requiring suppliers to cascade the same standard to their own sub-contractors.
• Seeking assurance that workers within our supply chain have access to a confidential grievance mechanism, retain their own identity documents and wages, and are not liable for recruitment fees (the "Employer Pays" principle).

Based on the findings of risk assessments and completed QP 106 questionnaires, Jaybee Supplies Limited will implement appropriate due diligence measures, up to and including a corrective action plan, audit, or termination of the supplier relationship, to mitigate modern slavery risks and ensure compliance with this policy.

Jaybee Supplies Limited will provide training and awareness-raising initiatives to ensure that employees and relevant stakeholders understand:

• The risks and impacts of modern slavery and human trafficking.
• How to recognise the signs of modern slavery and report concern effectively.
• Their responsibilities under this policy and relevant legislation.

Jaybee Supplies Limited will monitor compliance with this Modern Slavery Policy on an ongoing basis, including review of completed QP 106 questionnaires and any supporting evidence, and will review its effectiveness regularly to ensure that it remains relevant and fit for purpose. Non-compliance with this policy may result in disciplinary action, up to and including termination of employment or contractual relationship.

This Modern Slavery Policy will be communicated to all employees, contractors, and other relevant stakeholders, and will be made publicly available on Jaybee Supplies Limited's website. Any breaches of this policy or suspicions of modern slavery will be reported and investigated promptly, and appropriate action will be taken in accordance with applicable laws and regulations.

This Modern Slavery Policy will be reviewed annually and may be amended from time to time in response to changes in legislation, regulations, or business operations.

For further information about this Modern Slavery Policy or to report any concerns or suspicions regarding modern slavery or human trafficking, please contact Alex Holt.

 

QP37                                                                                    01-02-2026                                                                                    REV 2