Modern Slavery Policy.

Effective Date: 10 December 2025

Atura Group Limited will not knowingly tolerate slavery, servitude, forced or compulsory labour, human trafficking, child exploitation or other severe labour abuse in its operations or supply chains. We are committed to acting ethically, identifying risk and responding in a way that prioritises the safety and rights of affected people.

Purpose and Status

This policy supports the principles of the Modern Slavery Act 2015 and describes Atura’s approach to prevention, identification, escalation and remediation. It is not presented as a statutory annual statement under section 54 unless Atura confirms that the legal turnover and other conditions apply and completes the required financial-year, approval, signature and publication steps.

Scope

The policy applies to directors, employees, workers, agency staff, contractors, consultants and people acting for Atura. It also sets expectations for suppliers, manufacturers, decorators, printers, fulfilment providers, couriers, technology providers, labour providers and other business partners.

Our Business and Supply Chains

Atura provides print, promotional merchandise, clothing and workwear, signage and graphics, fulfilment and online ordering portals. Products and services may be produced directly by suppliers or through multiple subcontracting tiers in the UK, Europe and other international markets. Raw materials, component manufacture, assembly, decoration, packaging, warehousing and transport may occur in different countries.

Atura may not always have full visibility below its direct suppliers. We will not imply that complete visibility exists. Instead, we will seek better information over time, prioritising areas where the risk or potential harm is greater.

Risk Factors

Relevant risk indicators may include:

• manufacture in countries or sectors associated with weak labour enforcement or high levels of migrant, temporary or informal labour
• textiles, garments, electronics, raw-material extraction, agriculture-derived materials, packaging, logistics, warehousing, cleaning and labour agencies
• complex subcontracting, homeworking, unauthorised production sites or lack of worker visibility
• recruitment fees, withheld identity documents, restricted movement, threats, debt bondage, excessive or involuntary overtime, withheld wages or unexplained deductions
• prices or lead times that appear incompatible with lawful pay, safe production and reasonable working hours
• supplier reluctance to disclose production locations, labour arrangements, audit evidence or corrective action

Supplier Standards

Suppliers are expected to:

• comply with applicable labour, human-rights, health and safety and modern-slavery laws
• ensure employment is freely chosen and workers may leave after reasonable notice
• prohibit recruitment fees, forced deposits and improper retention of identity documents
• prohibit unlawful child labour and protect young workers from hazardous work
• provide lawful pay, working hours, rest, freedom from abuse and safe working conditions
• maintain appropriate grievance and reporting routes without retaliation
• apply equivalent expectations to relevant subcontractors and provide information when reasonably requested

Due Diligence

Atura will take a risk-based approach to supplier onboarding and review. Depending on risk, this may include questionnaires, policy and certification checks, production-location information, contractual terms, audit evidence, third-party platform information, customer requirements, adverse-information checks and discussion of corrective action.

Higher-risk orders or suppliers may require enhanced review before commitment. Absence of a certificate does not automatically prove abuse, and possession of a certificate does not remove the need to consider credible warning signs.

Employment and Recruitment

Atura will maintain lawful, transparent recruitment and employment practices. Identity and right-to-work checks will be conducted appropriately; workers will not be charged recruitment fees by Atura; terms and pay will be explained; and concerns may be raised without retaliation. Labour providers, if used, will be checked proportionately.

Training and Awareness

People involved in procurement, sales, supplier management, fulfilment and management will receive information appropriate to their role on warning signs, escalation, responsible purchasing and the risk that abrupt commercial action may harm victims. Awareness will be refreshed periodically and after material changes in risk.

Reporting Concerns

A suspected case of forced labour, trafficking, child exploitation or related abuse must be raised immediately with a Director or through Atura’s published confidential reporting route. If a person appears to be in immediate danger, emergency services should be contacted. Advice may also be sought from the UK Modern Slavery and Exploitation Helpline on 08000 121 700.

Reports will be treated sensitively and shared only as necessary to protect people, investigate and meet legal obligations. Atura will not tolerate retaliation against a person who raises a genuine concern in good faith.

Response and Remediation

Atura will assess credible concerns promptly and may seek specialist or authority guidance. The response will consider the safety and wishes of affected people and avoid an automatic termination that could increase harm. Actions may include protecting individuals, preserving evidence, requiring corrective action, increasing monitoring, suspending new work, notifying a customer or authority, and terminating a relationship where the supplier will not or cannot address the risk.

Monitoring Approval and Review

The Directors are accountable for this policy. Atura will monitor information reasonably available to it, which may include the number and coverage of supplier assessments, identified high-risk areas, training completed, concerns raised, corrective actions and outcomes. The policy will be reviewed at least annually.

If Atura becomes legally required to publish an annual modern-slavery statement, the statement will describe actual steps taken during the relevant financial year, including areas where information or performance remains incomplete. It will be approved by the board, signed by a director and published as required.