1. Purpose and Scope

Bio Green Wax Ltd (the "Company") sources vegetable oils, oleochemicals, waxes and renewable feedstocks from agricultural and processing supply chains in regions where forced labour, bonded labour and child labour are documented risks. Palm and palm kernel derivatives, coconut products, castor and other agricultural origins depend on plantation and smallholder labour, often recruited through intermediaries and frequently migrant. The Company treats this as its most material human rights risk.

This policy states the standards the Company requires of itself and of everyone in its supply chain, and the procedures by which those standards are assessed, monitored and enforced.

The Company's turnover is currently below the threshold at which section 54 of the Modern Slavery Act 2015 requires a slavery and human trafficking statement. The Company nonetheless applies the standards set out in this policy voluntarily, and will publish a statement in the form section 54 requires as soon as the threshold applies to it.

2. Policy Statement

The Company does not tolerate forced labour, bonded or indentured labour, prison labour used coercively, human trafficking, child labour, or any other form of modern slavery in its own operations or in its supply chain.

The Company expects every supplier to uphold the same standard, to require it of their own suppliers, and to be able to demonstrate on request how they do so. Commercial relationships are conditional on that expectation being met.

3. Prohibited Practices

The following are prohibited throughout the Company and its supply chain, without exception:

• Any work or service exacted under menace of penalty and not offered voluntarily.
• Retention of passports, identity documents, work permits or personal possessions, whether as security or for any other reason.
• Recruitment fees, deposits or debts charged to workers. Recruitment costs are the employer's cost; workers must never pay to obtain work.
• Debt bondage, including advances or loans structured so that a worker cannot leave employment freely.
• Withholding, delaying or deducting wages to bind a worker to their employer.
• Restrictions on a worker's freedom of movement, including locked accommodation, curfews unrelated to safety, or requiring permission to leave the workplace outside working hours.
• Employment of children below the applicable minimum working age, and any work by a person under 18 that is hazardous or interferes with compulsory education.
• Threats, intimidation, physical or sexual violence, harassment, or the involvement of security personnel in labour discipline.
• Excessive overtime, or overtime that is not genuinely voluntary.
• Obstruction of a worker's right to resign on reasonable notice, to join a trade union, or to bargain collectively where local law permits.

4. Our Own Operations

The Company employs a small professional workforce and does not operate plantations, processing plants or warehouses directly. Within its own operations the Company:

• Verifies the identity and right to work of every person it engages before employment begins, using original documents and without retaining originals.
• Provides every worker with a written statement of terms, in a language they understand, before or on the day they start.
• Pays at or above the applicable statutory minimum, directly to an account in the worker's own name, and makes no deduction that is not lawful and agreed.
• Uses only labour providers that are appropriately licensed where a licensing regime applies, and checks that licence before engagement.
• Permits any worker to terminate their employment on the notice stated in their contract, without penalty.

5. Supply Chain Risk Assessment

The Company assesses each supply chain on the combination of country risk, commodity risk and the visibility it has of the tier below its direct supplier. The following categories drive the level of due diligence applied:

Certification such as RSPO, ISCC or an equivalent scheme is treated as supporting evidence, not as a substitute for the Company's own assessment. A certificate does not close an enquiry where credible adverse information exists.

6. Supplier Requirements

Every supplier is required, as a condition of doing business with the Company, to:

1. Comply with this policy and with all applicable labour, employment and anti-trafficking law.
2. Confirm that no forced, bonded, trafficked or child labour is used at any site from which the Company's goods originate.
3. Confirm that no worker has paid a recruitment fee, and that no worker's identity documents are held by the employer.
4. Cascade equivalent requirements to their own suppliers and labour providers.
5. Permit the Company, or a party appointed by it, to verify compliance by questionnaire, documentation review or, where justified, site visit, on reasonable notice.
6. Notify the Company promptly of any allegation, investigation, enforcement action or credible report concerning forced labour or modern slavery in their operations or supply chain.

These requirements are incorporated into the Company's purchase contracts and supplier terms, together with a right to suspend performance and a right to terminate for material or unremedied breach.

7. Indicators and Escalation

The following are treated as indicators requiring escalation to the Compliance Officer, whether observed directly, reported by a third party or raised in credible public reporting:

• Workers who appear unable to leave a site, or whose accommodation is controlled by the employer and locked or guarded.
• Evidence that recruitment fees, deposits or wage advances have been charged to workers.
• Employer retention of passports or identity documents.
• Wages paid in cash to a third party, to a single account for multiple workers, or below the legal minimum.
• Workers unable to describe their own terms of employment, or whose contracts are in a language they do not read.
• Presence of workers who appear to be under 18 in hazardous roles.
• A supplier's refusal to answer labour questions, to allow contact with workers, or to permit a site visit.
• Credible NGO, media, trade-union or governmental reporting of forced labour at a named site, group or region in the Company's supply chain.

On escalation, the Compliance Officer assesses the information, decides whether to suspend purchasing pending enquiry, and where the concern is substantiated agrees a corrective action plan with defined actions, owners, deadlines and verification. Where workers have suffered loss — unpaid wages, unlawful fees, retained documents — remedy to those workers is a required element of the plan.

Where the Company has reasonable grounds to believe that a person is a victim of modern slavery or human trafficking, the Compliance Officer will ensure that the matter is referred to the appropriate authority, and in the United Kingdom will make a referral through the National Referral Mechanism or a report to the police where the circumstances require it.

8. Raising a Concern

Any worker, supplier, customer or member of the public may raise a concern about forced labour or modern slavery connected to the Company or its supply chain, by email or by post to the Compliance Officer, using the contact details at the end of this policy.

Concerns may be raised confidentially or anonymously. The Company will acknowledge a report where a contact route is given, will treat the identity of a reporter as confidential so far as the law allows, and will not retaliate against anyone who reports in good faith. Suppliers are required to make an equivalent grievance channel available to their own workers and to make it known to them in a language they understand.

9. Training, Monitoring and Review

Directors, employees and contractors receive training on the indicators of forced labour and modern slavery, on this policy and on the escalation route, on joining and at least annually thereafter. Staff responsible for sourcing and supplier management receive additional training on supply chain due diligence.

The Compliance Officer maintains the supplier risk register, records due diligence and corrective actions, and reports to the Board at least annually on supply chain risk, concerns raised, action taken and the effectiveness of this policy.

A breach of this policy by a director, employee or contractor is a disciplinary matter and may amount to gross misconduct. A breach by a supplier entitles the Company to suspend or terminate the relationship. This policy is reviewed at least annually, and sooner where a change in law, in sourcing origins or in the risk picture requires it.