This statement sets out NEOM’s actions to understand and eliminate all modern slavery risks and to put in place
steps aimed at ensuring there is no slavery or human trafficking within our own business and our supply chains.

NEOM are committed to acting ethically and with transparency in all our business operations and to ensuring 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.


We are the UK’s leading natural wellness brand with growing presence in the EU, the US and Asia. With headquarters in Harrogate and a new premises in 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.


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.

Whistle blowing 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. In 2022, we published a new 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.

Recruitment/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.


NEOM 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.


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. Where required this may include an independent on-site audit to review working conditions.

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.


All of 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 whistle blowing policy.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 2024.

This statement was approved by the Board of Directors of NEOM on 1st August 2023.