FINDRA Modern Slavery & Human Trafficking Statement

Financial Year 2026

1. Introduction and Policy Statement

Modern slavery is a crime and a serious violation of fundamental human rights. It takes many forms, including slavery, servitude, forced and compulsory labour, human trafficking and the exploitation of vulnerable workers, all of which deprive individuals of their freedom and dignity for personal or commercial gain.

At FINDRA, we are committed to acting ethically and with integrity in all our business dealings and relationships. We take a zero-tolerance approach to modern slavery, human trafficking, forced labour and the exploitation of workers.

We are committed to ensuring that these practices have no place in our business or supply chains. We recognise that this requires ongoing attention, transparency, appropriate supplier engagement and continuous improvement.

We are committed to operating responsibly and to increasing transparency in our approach to tackling modern slavery throughout our supply chains, in accordance with the principles of the UK Modern Slavery Act 2015.

2. Our Business and Supply Chains

FINDRA is a British outdoor clothing brand specialising in high-quality, responsibly sourced clothing designed for outdoor activities and everyday life.

Our supply chain includes the sourcing of raw materials, garment manufacturing, packaging and distribution. We work with manufacturing and supply partners in different countries, including the United Kingdom and China.

We source our merino clothing through Merino Ultimate, our specialist merino clothing supplier, and work with Diyang / Enjoy Wool. Diyang / Enjoy Wool is ISO 9001 accredited. While we have not visited the factory in person, we have worked with them for over 10 years and have met directly with the team we work with at European trade shows.

We recognise that products manufactured in different countries can carry different supply chain risks. We therefore believe it is important to understand not only where our garments are manufactured, but also where the raw materials originate and the conditions under which the people involved in their production work.

We expect all our suppliers, manufacturers, contractors and business partners to uphold high standards of ethical conduct and to take appropriate steps to prevent modern slavery throughout their own supply chains.

3. Our Ethical Sourcing Principles

We expect our suppliers and manufacturing partners to comply with applicable employment legislation and uphold internationally recognised human rights and labour standards.

In particular, we expect:

  • Voluntary employment: All employment must be freely chosen. Forced, bonded, compulsory, involuntary or prison labour is strictly prohibited.
  • Employment contracts: Workers should receive clear, legally compliant employment terms and conditions.
  • Fair remuneration: Workers must receive at least the applicable legal minimum wage, with fair and transparent payment arrangements.
  • Safe working conditions: Factories must provide safe, hygienic and appropriate working environments.
  • Working hours: Working hours must comply with applicable legislation and workers must receive appropriate rest periods.
  • No child labour: Child labour and the exploitation of young workers are prohibited.
  • Freedom and dignity: Workers must be treated fairly and with respect, without discrimination, intimidation, harassment or coercion.
  • No recruitment fees or document retention: Workers must not be forced to pay recruitment fees or surrender passports, identity documents or wages as a condition of employment.

We also expect our suppliers to ensure that these standards are communicated to and upheld by their own suppliers, subcontractors and manufacturing partners.

4. China and Higher-Risk Supply Chains

We recognise the particular human rights concerns associated with forced labour in certain regions of China, including the Xinjiang Uyghur Autonomous Region.

We are aware of the serious allegations and documented risks relating to the forced labour of Uyghur and other minority groups in this region.

FINDRA does not knowingly purchase products or materials produced using forced labour, including Uyghur forced labour, prison labour or any other form of involuntary labour.

We recognise that checking the location of garment manufacture alone is not sufficient. Raw materials can originate from different regions and pass through multiple suppliers before reaching the finished product.

We therefore consider the traceability of raw materials, including cotton and other fibres, to be an important part of responsible sourcing.

We expect our suppliers to provide appropriate information about the origins of materials, manufacturing locations and any subcontractors involved in production. We also expect them to take reasonable steps to identify and address risks of forced labour throughout their supply chains.

5. Supplier Due Diligence and Monitoring

We recognise that written policies and assurances alone are not sufficient to demonstrate that workers are being treated fairly.

We expect our suppliers and manufacturing partners to be transparent about their employment practices, factory conditions and supply chain arrangements.

Our approach to supplier due diligence includes seeking information and appropriate supporting documentation regarding:

  • The identity and location of manufacturing facilities.
  • The use of subcontractors and any additional manufacturing locations.
  • Employment contracts and workers' terms and conditions.
  • Wage arrangements and compliance with local employment legislation.
  • Health, safety and working conditions.
  • Policies and procedures prohibiting forced labour, human trafficking and worker exploitation.
  • The origin and traceability of raw materials.
  • Independent social compliance audits and factory inspections, where available.

We encourage the use of independent third-party social compliance assessments and appropriate factory inspections, including unannounced or semi-announced visits where possible.

We recognise the importance of confidential worker interviews and other methods of assessing actual working conditions, rather than relying solely on factory management assurances.

We will seek further information from suppliers where necessary to better understand the safeguards and monitoring arrangements in place.

6. Responsibilities and Accountability

The FINDRA Board of Directors has overall responsibility for ensuring that this policy reflects our legal and ethical obligations.

The Founder and CEO has primary responsibility for overseeing the implementation, review and effectiveness of this policy and for addressing concerns relating to modern slavery within our business and supply chains.

We expect everyone working for or on behalf of FINDRA, including employees, contractors, suppliers and business partners, to understand and uphold the principles set out in this statement.

7. Reporting Concerns

We take any concerns about modern slavery, forced labour or worker exploitation seriously.

We encourage employees, suppliers, business partners and other stakeholders to raise any concerns regarding working conditions or potential exploitation within our business or supply chains.

Concerns, comments and questions can be directed to:

hello@findraclothing.com

We will take credible concerns seriously and consider appropriate action, including reviewing supplier relationships where necessary.

8. Measuring Effectiveness and Continuous Improvement

We recognise that tackling modern slavery requires ongoing commitment and continuous improvement.

We aim to strengthen our understanding of our supply chains and improve transparency through:

  • Ongoing engagement with suppliers and manufacturing partners.
  • Seeking greater visibility of manufacturing locations and subcontracting arrangements.
  • Reviewing available factory inspection and social compliance documentation.
  • Improving the traceability of raw materials.
  • Identifying and assessing potential modern slavery risks, particularly in higher-risk geographical regions.
  • Reviewing and addressing concerns raised by employees, suppliers and other stakeholders.

We will continue to review our approach and seek opportunities to strengthen our due diligence and supplier monitoring processes.

9. Policy Review and Approval

This statement reflects FINDRA's commitment to ethical business practices, responsible sourcing and the prevention of modern slavery and human trafficking.

It will be reviewed annually and updated as our understanding of our supply chains and our due diligence processes develop.

This statement has been approved by the FINDRA Board of Directors.

Signed:

Alex Feechan

Founder & CEO

FINDRA

Date: 1/2/26

Review date: 1/2/27