Modern Slavery & Human Trafficking Statement

Loomella is a UK-based online department store operating at loomella.co.uk, offering thousands of products across categories including fashion, beauty, home & garden, electronics, sports, and more. We source products from a global network of manufacturers, distributors, and brands, predominantly in Asia, Europe, and the United Kingdom.

We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or supply chains.

Our supply chains span multiple geographies and product categories. They include:

• Tier 1 — Direct suppliers: manufacturers, brands, and distributors with whom we have a direct commercial relationship
• Tier 2 — Component and material suppliers: entities that supply raw materials, fabrics, packaging, and components to our Tier 1 suppliers
• Service providers: logistics, warehousing, technology, marketing, and professional services firms

We recognise that supply chains in certain regions and product categories — including fast fashion, electronics manufacturing, and agricultural raw materials — carry a higher inherent risk of modern slavery and forced labour. We focus our due diligence efforts accordingly.

We maintain the following policies relevant to modern slavery and ethical trading:

• Supplier Code of Conduct: All suppliers are required to agree to our Supplier Code of Conduct as a condition of doing business with us. The Code sets out minimum standards relating to forced labour, child labour, freedom of association, working hours, wages, and safe working conditions, aligned with the International Labour Organization (ILO) Core Conventions.
• Responsible Sourcing Policy: Sets out our expectations for ethical sourcing, including prohibition on the use of forced, compulsory, bonded, or trafficked labour at any stage of production.
• Whistleblowing Policy: Provides a confidential mechanism for employees, contractors, and supply chain workers to raise concerns about potential modern slavery or human rights abuses without fear of retaliation.
• Recruitment Policy:Ensures that our own hiring practices comply with UK employment law and that we do not engage with recruitment agencies that charge workers fees (consistent with the ILO’s definition of debt bondage).

We take the following steps to identify and address modern slavery risks in our operations and supply chains:

• Supplier onboarding: New suppliers complete a pre-qualification questionnaire covering labour practices, working conditions, and ethical compliance. We review responses and request supporting documentation (e.g. third-party audit reports, certifications) before approving new suppliers.
• Risk-based auditing: We prioritise audits for suppliers in high-risk geographies or product categories. Audits assess compliance with our Supplier Code of Conduct and are conducted by accredited third-party auditors (e.g. SMETA, SA8000, or equivalent).
• Corrective action plans: Where audits identify non-conformances, we require suppliers to implement documented corrective action plans within agreed timescales. Persistent or severe violations may result in suspension or termination of the supplier relationship.
• Supplier mapping: We are progressively mapping our supply chains beyond Tier 1 to improve visibility of sub-tier suppliers and raw material origins in higher-risk categories.
• Contractual obligations: Our standard supplier contracts include provisions requiring compliance with applicable laws on forced labour and human trafficking, and the right to audit.

We assess modern slavery risk across our supply chain using the following factors:

• Geography: sourcing from countries with high prevalence of forced labour, weak labour law enforcement, or limited civil society oversight
• Sector: product categories with known risks, including garment manufacturing, electronics assembly, and agricultural inputs
• Workforce profile: use of migrant workers, seasonal labour, or labour brokers
• Purchasing practices: short lead times, low price pressure, and last-minute order changes can increase worker vulnerability

Based on our 2025 assessment, we consider the highest-risk areas in our supply chain to be: garment manufacturing in South and Southeast Asia; electronics component assembly; and packaging materials sourced from regions with limited regulatory oversight. We are directing additional due diligence resources to these areas.

To measure the effectiveness of our actions, we track the following KPIs:

• Percentage of active Tier 1 suppliers who have signed and returned our Supplier Code of Conduct (target: 100%)
• Percentage of high-risk Tier 1 suppliers with a valid third-party audit on file (target: 100%)
• Number of modern slavery-related concerns raised via our whistleblowing channel
• Number of corrective action plans issued and completed within agreed timescales
• Percentage of new supplier onboardings that include modern slavery risk screening

We will publish our performance against these KPIs in future annual statements.

We believe education is essential to identifying and preventing modern slavery. Our approach includes:

• Staff training: All employees involved in procurement, supply chain management, and logistics receive training on recognising the signs of modern slavery, our reporting procedures, and their responsibilities under the Modern Slavery Act 2015.
• Awareness materials: We provide guidance materials to help employees understand what modern slavery looks like in a commercial context, including common indicators such as workers appearing controlled, unable to speak freely, showing signs of physical abuse, or having documents held by a third party.
• Supplier engagement: We communicate our expectations to suppliers through our Supplier Code of Conduct, onboarding documents, and regular engagement meetings.

Anyone who suspects modern slavery or human trafficking in our business or supply chains should report it immediately:

• Internal: ethics@loomella.co.uk (confidential)
• UK Modern Slavery Helpline: 0800 0121 700 (24/7, free, confidential)
• Gangmasters and Labour Abuse Authority (GLAA): 0800 432 0804
• Police: 999 (emergency) or 101 (non-emergency)

This statement has been reviewed and approved by Loomella senior management. We are committed to continuous improvement in our efforts to combat modern slavery and human trafficking and will review and update this statement annually.

Approved by: Loomella Management
Date: 25 May 2025