Modern Slavery Policy

This statement is published in accordance with Section 54 of the Modern Slavery Act 2015 and sets out the steps Phoenix 2 Retail has taken during the relevant financial year to prevent modern slavery and human trafficking in our business and supply chains.

Introduction

Phoenix 2 Retail is committed to conducting its business with integrity, transparency, and respect for human rights. Modern slavery, encompassing slavery, servitude, forced or compulsory labour, and human trafficking, is a grave crime and a fundamental violation of human rights.

We operate a strict zero-tolerance approach. We will not knowingly do business with any organisation or individual involved in any form of modern slavery, and we hold our entire supply chain to the same standard. This statement outlines the steps we have taken to identify, prevent, and respond to modern slavery risks across our business and supply chains.

Our Organisation

Phoenix 2 Retail is a wholesale and distribution business operating within the vape and nicotine products sector in the United Kingdom. Our supply chains include manufacturers, importers, and distributors of these products, together with a range of third-party service providers who support our operations.

Our Policies

Our approach to preventing modern slavery is set out in our Modern Slavery & Human Trafficking Policy, which applies to all employees, directors, officers, agency and seconded workers, volunteers, contractors, and suppliers at every tier of our supply chain. The policy is supported by our Whistleblowing Policy, Supplier Code of Conduct, and Equality & Diversity Policy.

Our policy commits us to:

• Engaging only with reputable, licensed employment agencies and verifying their licensing status
• Conducting right-to-work checks on all workers before employment commences
• Paying all workers directly and at or above the National Living Wage, with no unlawful deductions
• Never holding or retaining workers' identity documents or passports
• Ensuring all workers have written contracts in a language they understand
• Never charging recruitment fees to workers at any stage
• Providing workers with details of their rights, including the right to join a trade union

Due Diligence & Risk Assessment

We conduct an annual risk assessment covering geographic, sector, supplier, and workforce risk, reviewed whenever material changes to our supply chain or business activities occur.

Our supplier due diligence process includes:

• Completion of a Modern Slavery Supplier Self-Assessment Questionnaire for all new suppliers, within 90 days of onboarding
• Requiring all suppliers to confirm adherence to our policy as a condition of contract
• Specific anti-slavery and human trafficking contractual clauses in all supplier contracts
• Periodic supplier audits, including unannounced site visits where appropriate, for higher-risk suppliers
• Time-bound remediation plans where audit findings identify issues
• Annual self-declaration from all suppliers above a defined spend threshold
• Enhanced due diligence, including third-party audits or on-site assessments, for identified high-risk suppliers

Where a supplier is unwilling or unable to address identified concerns or meet our required standards within an agreed timeframe, we reserve the right to review and, where appropriate, terminate the commercial relationship.

Training & Awareness

All new starters complete mandatory modern slavery awareness training as part of their induction, with annual refresher training for all employees and management. Enhanced, role-specific training is provided to those involved in procurement, supply chain management, and HR. Completion of mandatory training is a condition of employment.

Reporting Concerns

Any employee, worker, or third party who believes or suspects that modern slavery is occurring can report their concern to their line manager, any member of the Executive Team, a company Director, or anonymously via our Whistleblowing Policy. No individual who raises a genuine concern in good faith will suffer any detriment as a result.

Concerns can also be raised confidentially with the following external organisations:

• Modern Slavery Helpline: 0800 0121 700 (free, 24 hours a day, 7 days a week)
• The Salvation Army (victim support): 0300 303 8151
• Gangmasters and Labour Abuse Authority (GLAA): 0800 432 0804
• Unseen UK: www.unseenuk.org

Measuring Effectiveness

We monitor the effectiveness of our anti-slavery measures against the following key performance indicators:

Approval

This statement was approved by the Executive Team and is reviewed and republished annually.

Date: 1st July 2026