Modern Slavery Policy

1.1 Modern slavery is a crime resulting in an abhorrent abuse of human rights. It is constituted in the Modern Slavery Act (“MSA”) 2015 by the offences of ‘slavery, servitude and forced or compulsory labour’ and ‘human trafficking’. Over 21 million people around the world are trapped in some form of forced labour. For this reason, Lintbells is dedicated to doing the best that we can to prevent and stop any unlawful behaviour taking place within our supply chain and business.

1.2 Lintbells Limited (“Lintbells”) opposes Slavery and Human Trafficking and will never knowingly conduct business with suppliers or employees who engage in such practice. It undertakes to remunerate employees at or above the minimum wage specified for that area of the world in which it is conducting business.

1.3 Lintbells conducts supplier audits of its regular suppliers. The audits are scheduled and review many aspects of the supply chain including the supplier’s policies towards environment, safety, child labour, quality control measures, slavery & human trafficking and other legal requirements. The audits also include onsite visits to our manufacturers.

1.4 Lintbells recognises that raw material procurement in some parts of the world may operate in a higher risk environment. It therefore only acquires raw materials through established parties recognised in its industry who operate quality control regimes and have either their own slavery and human trafficking policy in place or screen their suppliers for ethics. In addition in its supply agreements it requires the suppliers to certify that materials supplied comply with the laws of the countries in which those companies do business which would include legislation addressing human trafficking and slavery.

1.5 Lintbells recognises that raw material procurement in some parts of the world may operate in a higher risk environment. It therefore only acquires raw materials through established parties recognised in its industry who operate quality control regimes and have either their own slavery and human trafficking policy in place or screen their suppliers for ethics. In addition in its supply agreements it requires the suppliers to certify that materials supplied comply with the laws of the countries in which those companies do business which would include legislation addressing human trafficking and slavery.

1.6 Lintbells recognise that we have a responsibility to take a robust approach to slavery and human trafficking and Lintbells continue to take our responsibility very seriously during the coronavirus pandemic and beyond.

1.7 Lintbells is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

2.1 This policy covers the activities of Lintbells:

Lintbells is a UK based direct retailer of Pet Supplements, Vitamins and Healthcare Products. Lintbells sources its product ingredients from around the world using regular suppliers who satisfy quality criteria assessments.

2.2 Lintbells currently operate in the following countries:

• England
• Scotland
• Wales
• Ireland
• Northern Ireland
• EU - List TBC
• United States
• Other TBC

3. RELEVANT POLICIES AND PRACTICES

3.1 Lintbells operate the following policies and practices that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing policy - Lintbells encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can complete our confidential disclosure form].
• Employee code of conduct - Our code makes clear to employees the actions and behaviour expected of them when representing our organisation. Lintbells strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
• Supplier code of conduct - Lintbells are committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Lintbells work with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of our supplier code of conduct will lead to the termination of the business relationship. [Describe the process and steps taken to implement the code of conduct in relation to slavery and human trafficking, including examples (not necessarily named) where action has been taken to address specific slavery and human trafficking risks.]
• Recruitment/Agency workers - Lintbells use only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

4. DUE DILIGENCE

4.1 Lintbells undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. Our due diligence and reviews include:

• Evaluating the modern slavery and human trafficking risks of each new supplier by way of an approval form and filing copies of any relevant policies sent to Lintbells.
• Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• Conducting supplier audits or assessments, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• Taking steps to improve substandard suppliers' practices, including providing advice to suppliers and requiring them to implement action plans
• Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

5. DIRECTOR APPROVAL

5.1 This policy was approved by our directors on the 9 June 2021, who review and update it annually.