Modern Slavery and Human Trafficking

This statement sets out Supreme Imports Ltd’s (“Supreme”) actions to ensure that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2023 to 31 March 2024.

Supreme Imports Ltd is a 100% owned direct subsidiary of Supreme Plc, an AIM-listed holding company.

Supreme is the parent company for the trading subsidiary companies listed in the Schedule to this statement. This statement covers the activities of Supreme Imports Ltd and it’s listed subsidiaries.

Supreme is a vertically integrated platform business for fast-moving consumer goods, spanning four principal product categories (batteries, lighting, vaping and sports nutrition & wellness) across a number of operational disciplines including product development, manufacturing and distribution:

1. Batteries
   Supreme is one of Europe’s leading distributors of household batteries, able to supply a variety of wholesale domestic batteries (Duracell, Energizer, JCB and Panasonic) including dry cell, specialist and rechargeable.
2. Lighting
   Supreme has exclusive licence agreements with big-name lighting brands and are proud manufacturers and distributors of Eveready, Energizer, JCB and Lumilife lamps, as well as the PowerMaster brand of light fittings.
3. Vaping
   Supreme manufactures, imports and sells e-cigarettes and associated accessories, including e-liquids and disposable vapes. Supreme’s own brand and private label e-liquids are manufactured in its own UK facility, VN Labs.

   Supreme supply a range of formats across its vaping brands, including 88Vape, Liberty Flights, KiK and T-Juice. Supreme also buys and sells (wholesale and direct) 3rd party disposable vapes, including Elf Bar and Lost Mary.

4. Sport, Health & Wellness
   Supreme manufactures and sells health and wellness products across a number of ranges, including protein powders, nutritional snacks and drinks and vitamins and supplements. Supreme brands include Sci-Mx, Battle Bites, Sealions and Protein Dynamix.

   The Group’s UK manufacturing base (VN Labs) manufacturers and blends some of the Group’s range of powders and vitamins.

5. Drinks
   Supreme has also recently expanded into the soft drinks market with the acquisition of Clearly Drinks, adding established brands such as Perfectly Clear and Northumbria Spring to its portfolio. The acquisition was made in June 2024.

The majority of Supreme’s revenue is derived from its UK operations (more than 95% of group revenues for the financial year ending 31 March 2023 derived from the UK). Of the remaining revenues, the majority are derived from EU sales.

Supreme’s customer base includes a number of high street retailers, including Home Bargains and B&M, wholesalers, independent retailers and direct to consumer sales.

Supreme’s key supply chains are:

• Batteries are predominantly purchased directly from UK and European suppliers (including the Group’s Duracell, Energizer and Panasonic battery ranges).
• Lighting (which is produced by Supreme under license) is predominantly manufactured and imported from the Group’s selected Chinese manufacturers.
• Vaping:
  • raw materials suppliers for the Group’s e-liquid manufacturing are sourced from predominantly UK based suppliers; and
  • disposable and POD system vaping ranges are imported from Chinese manufacturers, including both the Group’s own brands and third-party brands such as Elf Bar.
• Sports Nutrition and Wellness suppliers (for both the group’s protein manufacturing facility, and finished goods) are predominantly UK or EU based suppliers.

Responsibility for the organisation’s anti-slavery initiatives is as follows:

• Policies: Supreme’s Human Resource department together with the Board of Directors and Supply Chain leadership are responsible for putting in place and reviewing policies which support Supreme’s anti-slavery initiatives.
• Investigations/due diligence: Supreme’s Board of Directors are responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.

Supreme operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing policy Supreme encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, Supreme. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
• Employee code of conduct Supreme’s code of conduct makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating and managing its supply chain.
• Supplier code of conduct Supreme are committed to ensuring that its suppliers adhere to the highest standards of ethics. Key suppliers are required to demonstrate that they act ethically and within the law in their use of labour. Supreme work with key suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of Supreme’s supplier code of conduct may lead to the termination of the business relationship.
• Recruitment/Agency workers policy Supreme uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
• Ethical Trading policy This policy outlines Supreme’s commitment to the core principles of the Ethical Trading Initiative (ETI) Base Code, which ensures the fair treatment of workers, ethical sourcing, and respect for human rights throughout our supply chain.

Supreme seeks to undertake due diligence when considering taking on new key suppliers, and regularly reviews its existing suppliers. Supreme’s due diligence and reviews may include:

• Reviewing the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
• Evaluating the modern slavery and human trafficking risks of each new key supplier;
• Conducting supplier assessments through Supreme’s own staff/third party auditor, which have a greater degree of focus on slavery and human trafficking where general risks are identified; and
• Using resources, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular.

We will continue to review the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains.

We have assessed the territories within which we carry out our business by reference to the Walk Free Foundation Global Slavery Index.

Based on Supreme’s supplier geographic footprint (predominantly UK and China), we are aware that, based on this index, the Group’s suppliers are not currently operating in locations with a high prevalence of slavery. This should not, however, give rise to complacency, and Supreme remains vigilant to the risks in its supply chain.

We have robust processes to combat modern slavery risks in our own workforce: we carry out right to work checks and adhere to minimum wage obligations.

Supreme monitors the following indicators to measure the effectiveness of its actions:

• Any reporting under the Group’s whistleblowing policies; and
• Any breach of Supreme policies by suppliers and any termination of supplier relationships relating to acts or omissions in connection with Supreme’s policies.

Supreme trains and briefs our HR personnel on the applicable policies and procedures relating to recruitment and right to work checks.

This statement has been approved by Supreme Imports Ltd’s Board of Directors, who will review and update it annually.

This statement was made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Group’s anti-slavery and human trafficking statement for financial year ending 31 March 2024. It was approved by the Board of Supreme Imports Ltd on the 27 September 2024.

Signed on behalf of the Board by Suzanne Smith – CFO and Director

Schedule – Group Companies (excluding currently non-trading entities)

Clearly Drinks trading (non-holding) companies (acquired June 2024)