Introduction

This statement outlines the actions undertaken by Cheeky Panda Limited to understand the risks presented by our business activities in relation to the issues of modern slavery. This policy also provides illustration of the steps we have put in place to ensure that our supply chain, and other aspects of our business are free of slavery and human trafficking.

Here at Cheeky Panda Limited we wholeheartedly condemn all such practices associated with modern slavery, human trafficking, and exploitation of persons. This comes not least from the perspective of a company with aims of contributing to social and environmental good, but simply from our position as decent citizens with morals, values, and basic human empathy.

As our business grows, as does our commitment and responsibility to ensure modern slavery does not exist in our supply chain. It is the responsibility of both Cheeky Panda and other companies in our sector, as well as society as a whole to take a robust approach to human trafficking and modern slavery.

Policy Statement

This policy applies to all parties working on behalf of Cheeky Panda Limited, including employees, directors, consultants, volunteers, and other representatives, as well as other relevant stakeholders, such as suppliers and partners.

Cheeky Panda Limited will not tolerate any form of slave labour or human trafficking in any part of our business. This is set out in our Code of Conduct which expresses our ethics as a company. Cheeky Panda Limited will terminate contracts and negotiations, as per the Ethical Trading Initiative (ETI), where the behaviour of other parties violates this policy, and where there is seemingly no willingness or desire to address such behaviour, or the incident from which the behaviour arises.

Accountability for this policy lies with the Directors of Cheeky Panda Limited, as does responsibility for its implementation. All allegations of modern slavery or human trafficking will be listened to, heard and ultimately dealt with in a robust and timely manner.

Purpose of this Policy

This statement relates to actions and activities during November 2025 and October 2026.

Cheeky Panda Limited is a sustainable organisation aiming to do good and be good, not just environmentally but socially too. Our operations span multiple continents, the purpose of this policy is to set out our approach to preventing modern slavery, human trafficking, and exploitation, in our own operations as well as the partners that assist the implementation of such operations in our supply chain. All staff will be made aware of this policy and will stand as a key feature within our Sustainability Report.

Scope of this Policy

This policy applies where Cheeky Panda Limited operates. Cheeky Panda expects all partners and supplier to abide by, and work towards this policy. We ask suppliers to meet sustainability requirements, for example confirming their sustainability performance and meeting anti-corruption requirements. We see a low risk of corruption, but we know that transparency can be a challenge. We will hereby take appropriate steps to address the risk of partners and suppliers not meeting this policy, and to fully address any complaints of non-compliant behaviour against these parties. We will act in response to these claims, with the course of action dependent on the associated issues and capacity of Cheeky Panda to address them.

Supply chain overview

Cheeky Panda Limited currently operates in the following countries:

• United Kingdom (Head Office)
• USA (American Subsidiary)
• Ireland (European Subsidiary)
• China (Chinese Subsidiary, source of materials and manufacture location)

The Cheeky Panda branded goods are further supplied in approximately 30 countries.

Risk Assessment

Cheeky Panda Limited identified manufacture in China as an activity of potential risk in relation to modern slavery and human trafficking, stemming from concerns regarding implementation of both human and workers’ rights laws in the country.

Cheeky Panda Limited, its suppliers, and partners are expected to comply with all applicable international human rights standards, national legislation, statutory requirements, and existing policies. The following steps were taken to ensure that the operations of The Cheeky Panda Limited, as well as those of our manufacturing partners, respected such compliance and aligned with our belief that everyone has the right to freedom from exploitation:

• Employee Legislation
• Health and Safety
• Workers’ Rights
• Workplace Complaints
• Lowest Hourly Wage
• Benefits
• Working Week
• Minimum Working Age
• Age Compliance Checks

Cheeky Panda Limited, its suppliers and partners, are aware of The International Labour Organisation (ILO) Indicators of Forced Labour. Individually, these indicators may not mean there has been modern slavery taking place but, when reported, claims will be investigated to assess the impact / threat to a worker, and corrective action implemented.

The 11 ILO Indicators of Forced Labour and examples (not limited to) are:

Abuse of worker’s vulnerability	Exploitative hiring / keeping in employment Due to language barriers, gender, age, economic need, immigration status etc.
Deception	Working conditions being different to what was promised Including wages, job type, housing, location etc.
Restriction of movement	Prohibited leaving the work site Locked or guarded in working site
Isolation	Isolated in remote areas which are hard to access Denied contact with outside world such as confiscation of mobile phones, kept in work / accommodation by locked doors
Physical or sexual violence	Any violence or threats of violence
Intimidation and threats	Verbal abuse and intimidation Loss of wages or access to privileges
Retention of identity documents	Confiscation of passports, qualifications or possessions
Withholding payment	Delayed payment Lack of control over bank account
Debt bondage	Workers are in employment for the reason of paying off a debt to the employer Debt creation Recruitment fees being charged by agencies to get them their job, which come at a very high cost. Can result in contracts being made for workers to pay off debts to recruiters, trapping them in debt.
Abusive living and working conditions	Overcrowding Unsanitary conditions Health and Safety breaches
Excessive overtime	No days off Denial of breaks Breaking limits prescribed by law

 

Business Social Compliance Initiative (BSCI) Audits

We have identified that there could be risks in relation to modern slavery and human trafficking in China, Annually, each supplier from China will be assessed by independent auditors, which conduct a BSCI audit. This ensures compliance with social and labour standards throughout our supply chain. This report must be shared with Cheeky Panda, through our project management system, Monday.com, and filed in the appropriate Supplier Information folder for reference.

The audit assesses:

• PA1: Social Management System
• PA 2: Workers Involvement and Protection
• PA 3: The Rights of Freedom of Association and Collective Bargaining
• PA 4: No Discrimination, Violence or Harassment
• PA 5: Fair Remuneration
• PA 6: Decent Working Hours
• PA 7: Occupational Health and Safety
• PA 8: No Child Labour
• PA 9: Special Protection for Young Workers
• PA 10: No Precarious Employment
• PA 11: No Bonded, Forced Labour or Human Trafficking
• PA 12: Protection of the Environment
• PA 13: Ethical Business Behaviour

The report enables us to monitor working conditions in our supply chain. In the case of non-compliances our China team, will monitor and communicate to us the development and completion of any corrective action plans required. Note, for any suppliers which do not hold a BSCI audit, they are required to complete a Sedex SMETA audit which again analyses working conditions and environmental performance.

Standards

In addition to legal compliance, Cheeky Panda Limited expects all staff, partners and suppliers to demonstrate commitment to meeting the following standards:

• Zero tolerance to inaction on exploitation
• Fair payment
• Upholding individual freedoms
• Both freedom from, for instance, coercion
• And freedom to – enter and leave employment, voluntarily and freely, etc.
• Maintenance of satisfactory and working conditions
• Fostering supportive culture and transparency

Commitments

Cheeky Panda Limited will ensure that:

A. All staff, volunteers, partners and relevant stakeholders will be able to access information relating to risk identification, as well as the ability to report concerns and make allegations of modern slavery and human trafficking. Any concerns should be reported to HR Manager, Fiona Breen.

B. All those parties listed above will have access to, and be aware of, this policy.

C. Those staff who will henceforth have specific responsibilities in relation to this policy will receive adequate and appropriate training.

D. All suppliers and relevant third-party partners have demonstrated they have equally sufficient checks and processes in place, ensuring compliance and alignment with this policy – in the case of policy breach, action will be taken, the content of which will be dependent on circumstantial factors, whilst also placing utmost importance on the effects of such actions upon those individuals impacted by the breach.

E. Allegations of modern slavery, human trafficking and associated activities will be taken seriously, investigated and appropriately acted on.

Key Data

Title of Policy	Modern Slavery and Human Trafficking Policy 2025/2026
Author	Fiona Breen, Senior HR Manager
Area of Governance	Corporate Responsibility
Effective Date	September 2024
Date for Review	October 2026
Approved by	Tom Mitchell, Chief Financial & Operating Officer
Status	Active

Reviewed: July 2026