The statement sets out the steps taken by Ultimate Products PLC and Ultimate Products UK Limited (Trading as Ultimate Products) to prevent modern slavery and human trafficking in its own business and supply chain for the financial year ending 31 July 2025, in accordance with section 54 of the UK Modern Slavery Act.
OVERVIEW & STRUCTURE
Ultimate Products (UP) is a Public Limited Company (PLC) and a leading retail brand house that designs, sources, and distributes its own branded consumer goods worldwide. We operate in the UK, China, and Hong Kong, and maintain a European showroom in Paris, France, as well as distribution centres in the UK and leased warehousing facilities across Europe.Our supplier base is primarily located in China, with a small number of suppliers in India and Europe, and our external logistics partners operate internationally to support global distribution.
As part of our broader Environmental, Social and Governance (ESG) strategy – which provides a framework for evaluating our impact on sustainability and ethical practices – we are committed to ensuring that the products we supply are sourced, manufactured and delivered in a fair, ethical and environmentally responsible manner. Upholding these standards is integral to our business, and we continuously review and strengthen our approach through our internal ESG governance structure. Modern slavery and ethical sourcing standards form a core component of the social (S) pillar within this framework.
We recognise the potential risks of modern slavery both within our own operations and across our supply chain. We are committed to understanding these risks in depth and working collaboratively with our suppliers and logistics partners to mitigate them. Our approach includes conducting annual risk assessments, monitoring performance regularly, and driving continuous improvement in our practices.
We operate a zero-tolerance approach to modern slavery and will not knowingly engage with any supplier or partner involved in slavery, human trafficking, or exploitation. Based on our risk assessments and established reporting channels, there is currently no indication of modern slavery within our operations or supply chains during this reporting period.
RISK & RESPONSIBILITY
Since its introduction in 2023, UP’s Compliance Department has played a leading role in ensuring compliance to both internal and external regulatory requirements. Modern slavery compliance remains a key responsibility, with the department conducting annual risk assessments and internal audits to identify areas for improvement. Findings are reported to UP’s Chief Supply Chain Officer (formerly Supply Chain Director) and Chief Operating Officer (formerly Group HR and Operations Director) and are escalated to the Board of Directors as appropriate.
Ethical and social compliance responsibilities are managed from the UK, ensuring strong oversight and alignment with regulatory standards. All factories supplying UP are audited by accredited third party audit houses against the Ethical Trading Initiative (ETI) Base Code, an internationally recognised benchmark for workers’ rights and ethical trade practices.
Our ongoing partnership with Verisio has further strengthened our due diligence processes. This partnership aims to strengthen our supplier base, drive continuous improvement, and enhance our ability to identify, reduce, and mitigate risks. As part of this process, Verisio assesses and manages all UP Tier 1 manufacturing sites against our requirements. The onboarding of all active UP suppliers began in May 2024, with the Optimus platform launched at the start of FY25 (August 2024).
By year-end (July 2025), all live Tier 1 suppliers were onboarded onto the Optimus platform, with new suppliers being added within one month of engagement by the sourcing and buying teams. 98.1% of live suppliers had a valid ethical audit on file, with the remainder having renewal audits booked. Engagement with the platform reached 72%, and 48% of suppliers met the minimum standard requirements set out to them. The number of high risk suppliers decreased, reflecting a positive shift in risk ratings across the supplier base since initial gradings.
ANNUAL RISK ASSESSMENT
Throughout FY25, UP continued to strengthen its commitment to combating modern slavery across its operations and supply chain. Building on the FY24 internal risk assessment, the Compliance Department launched a two-year Modern Slavery Responsibility Plan aimed at enhancing internal processes and preparing UP to become a Stronger Together Business Partner.
The annual modern slavery risk assessment for FY25 was completed in June 2025, resulting in a reduction of required actions from 25 in FY24 to 13 in FY25, demonstrating meaningful progress in mitigating modern slavery risks. At the end of FY25, UP was awarded Stronger Together Advanced Business Partner status ahead of schedule, reflecting the additional work completed on action items and the overall progress made throughout the year.
Key actions delivered in FY25 included:
The FY25 risk assessment highlighted additional opportunities to strengthen UP’s approach, including:
These actions will be completed within the next financial year ending 31 July 2026 and will form the basis of our ongoing two-year responsibility plan. Collectively, these efforts reflect UP’s continued commitment to ethical business practices, transparency, and proactive risk management in line with its ESG objectives.
OUR SUPPLIER BASE
We maintain active membership with SEDEX and AMFORI, two globally recognised platforms that champion ethical supply chain practices. The organisations provide robust tools and auditing frameworks to evaluate social compliance, labour standards, and human rights across international supply chains. Through these memberships, we reinforce ethical working practices within our supplier network, ensuring compliance with international standards and reducing risk of modern slavery or human trafficking.
All suppliers, both new and existing, must acknowledge and commit to our Modern Slavery Declaration annually via the Capture supplier management tool. For new suppliers, this requirement is introduced during initial onboarding discussions, and the signed declaration must be returned by a senior member of their management team. Existing suppliers reaffirm this commitment each year. All declarations are securely stored at our UK head office and reviewed periodically.
Our UP Supplier Manual outlines our expectations and compliance requirements. It is issued during onboarding and must be signed by suppliers before orders are placed. The manual update was finalised in January 2025 and distributed to suppliers at the end of February 2025.
The revision included:
The UP Code of Conduct sets clear expectations for suppliers, including:
This Code of Conduct is communicated to our supply chain annually, alongside modern slavery and anti-bribery confirmations, which must be digitally signed by all active suppliers. As part of this communication, we include details of our whistleblowing mechanism, enabling suppliers to confidentially report any concerns related to modern slavery, human trafficking, or other breaches or concerns. This ensures suppliers have a clear and safe channel to inform us of issues without fear of retaliation. This process is managed by the Compliance department.
To support responsible sourcing, all factories within our supplier base must maintain a valid ethical audit and complete corrective actions for any non-conformances. Our audit requirements include:
Accepted audit methodologies:
Accepted audit firms:
Accepted audit announcement types:
Audit reports can be rejected for any of the following reasons:
Regular monitoring, supported by factory visits from our UK and GZ teams, ensures ongoing visibility of ethical standards and progress on corrective actions.
RESPONSIBLE SOURCING
We remain committed to responsible sourcing and prioritise certified materials wherever possible. For timber based products, packaging, and printed materials, we require FSC certification includes auditing elements around the traceability of materials, but also checks on health, safety, and labour practices. FSC certification is globally recognised for promoting sustainable forestry, biodiversity protection, and respect for workers’ rights. By choosing FSC-certified materials, we support sustainable forest management, promote social responsibility, and contribute to the fight against deforestation.
In addition to FSC, UP achieved the Global Recycled Standard (GRS) certification during FY25, reinforcing our commitment to sustainable material sourcing. GRS certification verifies the recycled content of production and ensures compliance with strict environmental, social, and chemical criteria throughout the supply chain. This certification also requires robust chain of custody processes and third-party audits, providing assurance that our recycled materials are responsibly sourced and processed. By obtaining GRS certification, we strengthen our efforts to reduce environmental impact and promote circular economy principles across our product range.
OUR SUPPLY CHAIN PARTNERS
We actively monitor the transparency statements of our supply chain partners and maintain key contact details to enable swift engagement on any concerns. Periodic visits to UK and EU warehouse partners are conducted by UP teams, and any issues identified are escalated to the Compliance department for investigation.
UP TEAMS & RESOURCING PARTNERS
Our HR department operates robust procedures to identify and mitigate risks of modern slavery within both UK and Far East operations. These procedures are regularly reviewed to ensure effectiveness. UP avoids using recruitment agencies for temporary staff, reducing exposure to labour exploitation risks. Workforce planning is managed internally to maintain operational flexibility while safeguarding ethical standards.
Our dedicated HR resource based in our Guangzhou, China office supports UK operations by monitoring workforce conditions and providing guidance on modern slavery awareness. Internal teams receive annual training to identify and report any indicators of forced labour. A confidential whistleblowing mechanism is available to all staff, ensuring concerns can be raised safely and acted upon promptly.
FAIR PAY
We are committed to providing fair pay for our workers and offer a range of colleague benefits and financial incentives that demonstrate this. In the UK, we are committed to offering pay rates that exceed the National Living Wage and are striving to achieve UK Living Wage accreditation in the coming years. During the financial year ending 31 July 2025, our entire UK workforce was paid a minimum of £11.50 per hour (Temporary roles) and £12.50 per hour (permanent positions), irrespective of age or gender, which were above the current National Living Wage rates.
TRAINING & AWARENESS
We require all key staff involved in our supply chain to complete modern slavery training, ensuring they understand the risks of modern slavery, forced labour and human trafficking within the business, its suppliers, and supply chain partners. Internal training remains a priority:
Future plans for improvements include:
We will also continue to periodically review internal policies and procedures to ensure their effectiveness, particularly in the event of major organisational changes, the introduction of new legislation, the enhancement of existing legislation, or any breach of policy.
OUR POLICIES
We encourage all colleagues, workers, suppliers, and supply chain partners to report any suspected breach of our standards, with full assurance that they can do so without fear of retaliation. To support this, we have established a range of policies and procedures, and confidential reporting mechanisms that make it easy and safe to report concerns. These include:
TARGETS & KEY PERFORMANCE INDICATORS
To measure the effectiveness of our efforts in preventing modern slavery and human trafficking within our business and supply chain, we track the following key performance indicators:
| AREA | TARGET | FY25 PERFORMANCE |
| Ethical Supplier Base | 100% of suppliers to be audited | 98.1% (additional 1.5% suppliers with audits booked) |
| Reported cases of Modern Slavery via Compliance or HR teams | 0 | 0 |
| Reported cases of Modern Slavery via Whistleblowing procedure | 0 | 0 |
| Number of new & existing suppliers signed up to Modern Slavery statement on CAPTURE | 100% | 98% (100% for China suppliers) |
| Number of live suppliers signed up to UP Supplier Manual (latest version) | 100% | 98.1% |
We remain committed to continuous improvement and close collaboration with suppliers and partners. Key focus areas include:
• Ethical audits – Maintain over 98% audit completion for live suppliers, ensuring any outstanding audits are scheduled promptly for renewal.
• Corrective actions and engagement – Increase supplier engagement on the Optimus platform to reduce high-risk non-conformances and improve overall risk gradings. Verisio will host a dedicated supplier webinar in FY26.
DECLARATION
This statement will be reviewed annually by the Board of Directors, with any necessary changes implemented thereafter. Andrew Gossage was authorised by the Board to sign this statement on their behalf.
This statement has been published in accordance with the UK Modern Slavery Act 2015, which requires businesses to disclose publicly the steps they are taking to tackle modern slavery each year.
Signed By:
Chief Executive Officer
Andrew Gossage