Modern Slavery Policy

The Washroom Vanity Company is committed to promoting ethical business practices and ensuring that no acts of modern slavery or human trafficking take place within our business or supply chains. We acknowledge our responsibility under the Modern Slavery Act 2015, and this statement is made in line with the latest 2025 guidance and anticipated statutory reporting requirements, including greater transparency and accountability.

We adopt a zero-tolerance approach to modern slavery and human trafficking and continue to enhance our systems and controls to mitigate such risks across our operations.

Our Business and Structure

Our supply chain consists primarily of suppliers based in the UK and Europe, enabling a higher level of visibility and control. Where our supply chain extends beyond the UK and EU—particularly in higher-risk regions—we apply enhanced scrutiny and oversight, aligned with evolving best practice expectations in 2025.

Our Commitments

Our key commitments in relation to modern slavery and human trafficking include:

• A zero-tolerance stance toward slavery and human trafficking.
• Full compliance with the Modern Slavery Act 2015 and its expected 2025 updates.
• Integrating modern slavery risk assessments in supplier onboarding and ongoing management.
• Preferring suppliers who demonstrate strong ethical practices, and, where applicable, independent audit accreditations.
• Applying increased diligence for suppliers in countries or industries known for elevated risk.

Policies and Governance Enhancements (2025 Focus)

To align with the latest 2025 guidance, we have enhanced our governance framework as follows:

• Single annual statement: As proposed in 2025 reforms, we publish a consolidated statement covering all areas of required disclosure.
• Central registry: This statement will be submitted to the UK Government’s planned central public registry of modern slavery statements, once live.
• Standardised content: We address all mandatory reporting areas, including:
  • Organisation structure and supply chains
  • Policies in relation to slavery and human trafficking
  • Due diligence processes
  • Risk assessment and management
  • Key performance indicators
  • Training

Risk Assessment and Supply Chain Monitoring

We identify and manage modern slavery risks through the following steps:

• Supplier risk segmentation based on country, sector, and labour profiles.
• Due diligence checks during supplier onboarding, including compliance with labour laws and ethical sourcing standards.
• Preference for working directly with product sources where possible, particularly those subject to independent auditing.
• Ongoing review and consolidation of procurement policies to ensure sustained compliance.

Imported goods from outside the UK and EU remain a focus area due to increased inherent risks. These suppliers are subject to heightened review and management controls.

Recruitment and Employment Practices

• We engage only reputable recruitment agencies that adhere to strict eligibility, documentation, and right-to-work checks.
• Our internal HR policies prohibit forced labour and are designed to protect workers from exploitation.
• All staff have the right to work freely and are employed in accordance with UK employment law and best practice.

Looking Ahead: 2025 and Beyond

In line with anticipated legislative reforms, we are:

• Preparing for mandatory digital reporting to the government registry
• Aligning our reporting content with the proposed standard template
• Reviewing our supplier terms and codes of conduct to embed compliance requirements
• Enhancing our supplier contract clauses on labour standards and ethical conduct

Board Approval

This statement was approved by the Board of Directors.

This policy is available to interested parties, including the general public via the company’s website.