Reflo Modern Slavery and Human Trafficking Statement

 Introduction

Reflo is committed to conducting business responsibly and ethically. Modern slavery and forced labour of any kind have no place in responsible supply chains. This statement sets out our commitment to prevent modern slavery and human trafficking within our own operations and throughout our supply chain and business relationships.

 Our Commitment

We strictly prohibit all forms of forced labour, including but not limited to bonded labour, prison labour, indentured labour, debt servitude, and any form of coerced or involuntary work.

We recognise our responsibility to uphold human rights in all areas of our business, consistent with internationally recognised frameworks including the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the ETI Base Code.

 Policies and Governance

Our approach to modern slavery and human rights is guided by our Human Rights Policy, Responsible Business Conduct Policy and Supplier Code of Conduct, which together define our standards and expectations for ethical conduct across our operations and supply chain.

Key principles include:

Upholding human rights and fair working conditions across all business activities.

·      Aligning with the Ethical Trading Initiative (ETI) Base Code, particularly in relation to the following elements:

o   Employment is freely chosen — no worker is required to lodge deposits or identity papers, and workers are free to leave employment with reasonable notice.

o   Working hours are not excessive — overtime is voluntary and within legal limits.

·      Conducting Human Rights Due Diligence (HRDD) to identify and address potential risks in our supply base.

·      Embedding responsible business practices across sourcing, CSR, operations, and leadership roles.

·      Using risk assessments, audits, and stakeholder engagement to inform decision-making.

·      Requiring suppliers to comply with recognised audit standards (SMETA, BSCI, WRAP, Fair Wear) and to cascade these standards throughout their own supply chains. 

 Implementation and Responsibility

 We take a risk-based approach to assessing and managing human rights and modern slavery risks. This includes

Integrating human rights considerations into sourcing and supplier onboarding processes.

·      Engaging with suppliers and other stakeholders to build awareness and capacity.

·      Acting to prevent, mitigate, or remediate harm where risks are identified.

·      Oversight of our approach sits with the Reflo leadership team, with cross-functional responsibility built into relevant business functions.

Reporting and Grievance Mechanisms

 We encourage all employees, partners, and stakeholders to speak up if they experience or witness any form of modern slavery or unethical labour practices

Employees can raise concerns through our internal grievance procedure.

·        External stakeholders (including suppliers, contractors, and partners) can contact us confidentially at support@reflo.com.

All reports are taken seriously and will be investigated. Breaches of our standards may result in termination of employment, partnerships, or business relationships.

Continuous Improvement

While we are currently below the turnover threshold for mandatory reporting under the UK Modern Slavery Act 2015, we are committed to maintaining transparency and continuously improving our approach. As our business grows, we will expand this statement to include measurable actions, progress, and performance indicators.