MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

Introduction

Introduction

This statement sets out NEOM Wellbeing's actions to understand and minimise all modern slavery risks and to put in place steps to ensure that there are no slavery or human trafficking issues within our own business and identifying and remediating any negative impacts we have caused or contributed to in our supply chains.

NEOM Wellbeing are committed to acting ethically and with transparency in all our business operations and to ensure effective processes and controls are in place so that all our employees, business partners and extended communities are treated with respect and integrity and that we do not engage directly or indirectly with slavery or human trafficking. NEOM is committed to respecting human rights as set out in the:

● UN Declaration of Human Rights;
● UN Guiding Principles on Business and Human Rights; and the
● International Labour Organisation Fundamental Principles and Rights at Work

ORGANISATION STRUCTURE AND SUPPLY CHAINS

We are the UK’s leading wellbeing brand with a growing presence in the EU, the US and Asia. With headquarters in Harrogate and London, England, and several retail stores in the UK and Ireland, our principal business is the conception, distribution and supply of NEOM Wellbeing home fragrance and personal care products.

The manufacture of our products is conducted by specialist third party suppliers, we also have supply chain networks that facilitate the storage and transportation of our products and the operation of our retail stores.

The scope of this statement covers all individuals and communities affected by the company’s own operations and its value chain.

POLICIES AND STANDARDS

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

Whistleblowing policy: We 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.

Anti-Corruption and Bribery Policy: Our policy makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.

Supplier/Procurement Code of Conduct: We have a zero-tolerance policy to working with anyone that is involved in any illegal or unethical conduct, such as human trafficking, child labour or the use of slavery. Our Supplier Code of Conduct, this sets out all our expectations from an Ethical and Environmental perspective and includes specific reference to our Modern Slavery due diligence.

Agency Workers: We use only specified, reputable employment agencies to source labour and always verify the practices of any new agency before accepting workers from that agency. Agencies are required to fill in an ESG questionnaire so that we can assess their current policies (e.g. on Living Wages, working hours and child labour).

DUE DILIGENCE PROCESS 

NEOM Wellbeing undertakes due diligence, when considering any new suppliers and regularly reviews its existing partners, stakeholders and suppliers to ensure values and standards are consistent with our own. Preliminary risk assessments are conducted based on geographical mapping of high-risk countries for slavery and human trafficking, as well as consideration of the item purchased, supplier performance and the nature of the business transaction.

PERFORMANCE INDICATORS AND COMPLIANCE 

Suppliers are required annually to complete our ‘Supplier Screening’ questionnaire and 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. We ensure an on-site audit is completed every two years to review the social impact, health and safety procedures, environmental impact and policies are in place and adhered to. We work with suppliers to ensure that they meet our standards and make improvements where required. Serious violations will lead to the termination of the business relationship.

TRAINING 

All our employees know they have a role to play in the integrity of our supply chains and they all receive access to the relevant policies and regular updates are published in the staff handbook to which they are notified, specific training is provided to relevant members of staff based on their role however all employees complete annual training on Modern Slavery and it is a key part of our onboarding process.

We encourage and support our employees to identify any suspected misconduct, including violation of labour laws or unethical labour practices through our whistleblowing policy.

STEPS TAKEN

In the past financial year we have undertaken a project to increase supply chain visibility which included working with a sample of our main suppliers. The information collected during this process has allowed us to begin identifying social risks based on commodities and locations. This groundwork will help us with the next phase of our Human Rights Due Diligence
process.

IMPROVEMENT

In the next 12 months we will undertake a human rights saliency assessment with the help of an external expert. The process will include looking at trusted databases as well as undertaking stake holder engagement. This assessment will allow us to identify the most significant risks in our value chain. We will then identify the highest impact procurement actions we can take as well as any gaps in our current sourcing guardrails. We will review our grievance mechanisms and escalation process.

GOVERNANCE

The ultimate responsibility for monitoring our human right due diligence sits with our Executive team and Board of Directors. The responsibility for implementing and maintaining our social responsibility measures sits with our HR Manager, Sustainability Manager and Operations team.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and reflects the actions and activities during the financial year ending 30th June 2026 and has been approved by myself and the CFO.

Isabel Malbois
CEO