pg. 4

“The Group’s policies are aligned to and ensure adherence to local law, international labour standards and the Ethical Trading Initiative (ETI) Base Code, which covers the following key principles:

1. employment is freely chosen, 2. freedom of association and the right to collective bargaining are respected, 3. working conditions are safe and hygienic, 4. child labour shall not be used, 5. living wages are paid, 6. working hours are not excessive, 7. no discrimination is practised, 8. regular employment is provided, 9. no harsh or inhumane treatment is allowed.”

“By auditing against the ETI Base Code, Joules seeks to ensure that no forced, bonded or child labour is used by any of the factories it works with.”

“Joules’ modern slavery commitments are captured in both its Responsibly Joules Ethical Trading Policy, focused on internal commitments to ethical trade and expectations of strategic partners including the “Friends of Joules” sellers, and the Supplier Ethical Trading Policy, focused on the ethical trade requirements of Joules’ supply chain which all suppliers must adhere to.”

“Joules’ policies are clearly communicated to all suppliers, and each supplier is required to sign up to its terms and conditions which include compliance to policy documents when onboarded by Joules.”

Pg. 5

“Garden Trading’s commitment to safeguarding human rights is captured in its Sourcing with Care Policy. This requires suppliers to follow the ETI Base Code principles, which includes no child labour or forced labour, and to fulfil their legal obligations regarding human rights, and labour and modern slavery.”

Pg. 8

“Through the ETI Base Code Clause 1 “employment is freely chosen”, Joules commits to understanding forced labour, identifying the risks within the business’s own operations and supply chains, and to embed this understanding in policies and actions.”