Modern Slavery and Human Trafficking

This statement sets out Supreme Imports Ltd’s (“Supreme”) actions to ensure that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2024 to 31 March 2025.

Supreme Imports Ltd is a 100% owned direct subsidiary of Supreme Plc, an AIM-listed holding company.

Supreme is the parent company for the trading subsidiary companies listed in the Schedule to this statement. This statement covers the activities of Supreme Imports Ltd and its listed subsidiaries. Supreme’s subsidiaries are predominantly UK based, other than its Irish subsidiary. Any other non-UK subsidiaries are dormant/non-trading.

Supreme is a vertically integrated platform business for fast-moving consumer goods, across three operating divisions: Vaping (previously known as ‘Vaping’ and ‘Branded Distribution’), Drinks & Wellness (‘Sports Nutrition & Wellness’ combined with Typhoo Tea and Clearly Drinks), and Electricals (previously ‘Batteries’ and ‘Lighting’):

1. Electricals
   1. Batteries
      Supreme is one of Europe’s leading distributors of household batteries, able to supply a variety of wholesale domestic batteries (Duracell, Energizer and JCB) including dry cell, specialist and rechargeable.
   2. Lighting
      Supreme has exclusive licence agreements with big-name lighting brands and are proud manufacturers and distributors of Eveready, Energizer, JCB and Lumilife lamps, as well as the PowerMaster brand of light fittings.
2. Vaping
   Supreme manufactures, imports and sells e-cigarettes and associated accessories, including e-liquids and disposable vapes. Supreme’s own brand and private label e-liquids are manufactured in its own UK facility, VN Labs.Supreme supply a range of formats across its vaping brands, including 88Vape, Liberty Flights and KiK. Supreme also buys and sells (wholesale and direct) 3rd party disposable vapes, including Elf Bar and Lost Mary and IVG.
3. Drinks and Wellness
   1. Sports Nutrition & Wellness
      Supreme manufactures and sells health and wellness products across a number of ranges, including protein powders, nutritional snacks and drinks and vitamins and supplements. Supreme brands include Sci-Mx, Battle Bites, Sealions and Protein Dynamix.The Group’s UK manufacturing base (VN Labs) manufacturers and blends some of the Group’s range of powders and vitamins.
   2. Drinks
      Supreme has also recently expanded into:
      1. the soft drinks market with the acquisition of Clearly Drinks, adding established brands such as Perfectly Clear and Northumbria Spring to its portfolio. The acquisition was made in June 2024; and
      2. tea, with the acquisition of the iconic British brand Typhoo Tea in November 2024. Since acquisition, Supreme has brought manufacturing back in-house and has opened a dedicated tea manufacturing facility in Gloucester.

The majority of Supreme’s revenue is derived from its UK operations (more than 90% of group revenues for the financial year ending 31 March 2025 derived from the UK). Of the remaining revenues, the majority are derived from EU sales.

Supreme’s customer base includes a number of major supermarkets and high street retailers, including Home Bargains and B&M, wholesalers, independent retailers and direct to consumer sales.

Supreme’s key supply chains are:

• Batteries are predominantly purchased as finished goods directly from UK and European suppliers (including the Group’s Duracell and Energizer battery ranges).
• Lighting (which is produced by Supreme under license) is predominantly manufactured and imported as finished goods from the Group’s selected Chinese manufacturers.
• Vaping:
  • raw materials suppliers for the Group’s e-liquid manufacturing are sourced from predominantly UK based suppliers; and
  • finished product vaping ranges (not e-liquids) are imported from Chinese manufacturers, including both the Group’s own brands and third-party brands such as Elf Bar.
• Sports Nutrition and Wellness suppliers (for both the group’s protein manufacturing facility, and finished goods) are predominantly UK or EU based suppliers.
• Soft Drinks suppliers (predominantly cans and bottles) are purchased from UK suppliers for the Group’s manufacturing/production facility in Sunderland.
• Tea suppliers (mainly raw tea supplies) are predominantly based in the UK, with tea blends sourced from Africa.

In addition to product/business division specific supply chains, the Supreme group also procures the provision of services to support its business including:

• Logistics, storage and transportation providers who provide services to store and transport the group’s finished products to its customers;
• Cleaners, security and other facilities management to support the group’s operating premises;
• Professional services, including IT, accounting, tax and legal.

Responsibility for the organisation’s anti-slavery initiatives is as follows:

• Policies: Supreme’s Human Resource department together with the Board of Directors and Supply Chain leadership are responsible for putting in place and reviewing policies which support Supreme’s anti-slavery initiatives.
• Investigations/due diligence: Supreme’s Board of Directors are responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.

Supreme operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations. These policies have been implemented with board oversight, and with support from the group’s HR, legal and procurement teams and divisional leads:

• Whistleblowing policy Supreme encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, Supreme. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers (and others) to make disclosures, without fear of retaliation. Disclosures can be made anonymously where desired. Any reporting under the policy is reviewed and investigated by the group’s HR and legal function, with escalation to company directors and audit committee where appropriate.
• Employee code of conduct Supreme’s code of conduct makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating and managing its supply chain.
• Supplier code of conduct Supreme is committed to ensuring that its suppliers adhere to the highest standards of ethics. Key suppliers are required to demonstrate that they act ethically and within the law in their use of labour. Supreme work with key suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of Supreme’s supplier code of conduct may lead to the termination of the business relationship.

  During the most recent financial year, Supreme also updated its standard supplier terms and conditions, including to ensure the inclusion of a contractually enforceable obligation on a supplier to comply with UK modern slavery legislation as well as Supreme’s mandatory policies on modern slavery. Future steps may include increased audit of supplier compliance.

• Recruitment/Agency workers policy Supreme uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
• Ethical Trading policy This policy outlines Supreme’s commitment to the core principles of the Ethical Trading Initiative (ETI) Base Code, which ensures the fair treatment of workers, ethical sourcing, and respect for human rights throughout our supply chain.
• Rainforest Alliance and ETP Following its acquisition of Typhoo Tea in November 2024, Supreme has become a member of both the ETP (formerly the Ethical Tea Partnership) https://etp-global.org/ and the Rainforest Alliance https://www.rainforest-alliance.org/, and the Group’s tea is sourced in accordance with the policies and principles of both organisations, which seek to protect and uphold the rights of workers in the supply chain, with tea supplies procured only from Rainforest Alliance accredited gardens.

The group has recently, in 2025, implemented a new HR system, which has the facilitated an improved ability to ensure that key policies are shared with, and read and acknowledge by employees within the business. The system includes accessibility on personal mobile devices, to ensure access is possible for employees who don’t otherwise use a company issued device. Policies appliable to suppliers are shared during initial onboarding processes and otherwise as and when required (e.g. in the case of an update required to be communicated to a supplier).

In order to assess risk to workers, we have assessed the territories within which we carry out our business, including by reference to the Walk Free Foundation Global Slavery Index.

Based on Supreme’s annually undertaken risk assessment and its supplier geographic footprint (predominantly UK and China), we are aware that, based on this index, the Group’s suppliers are not currently operating in locations with a high prevalence of slavery. This should not, however, give rise to complacency, and Supreme remains vigilant to the risks in its supply chain.

In addition to our high-level geographic risk assessment, we also assess specific divisions within our group, and specific suppliers, based on location, sector/product, supplier tier, and specific knowledge/experience of suppliers including through a review of on-boarding surveys/questionnaires and any independent third-party compliance reports we receive. These assessments are predominantly conducted by our procurement department, together with our divisional leads. This assessment includes the following, which were assessed as being at a slightly more elevated risk:

• With our entry into the tea sector, we were aware of the sector specific issues that had been reported in respect of workers on tea plantations. We assessed the risk assessment and policies and procedures implemented by the Typhoo business before our acquisition, which included its own internally generated and manged ‘fear-free’ programme. Given our understanding that the potential risks exist across the tea sector and not just in a single brand, we sought to join reputable third-party programmes which support a broader reach of workers and countries, including Rainforest Alliance, of which we are now a member. We believe that being part of these third-party programmes/NGOs provides the most effective method to minimise risk in our supply chain, and support wider endeavours in the sector.
• Whilst China is not automatically highlighted as at risk of a high prevalence of slavery under the Walk Free Foundation Global Slavery Index, our suppliers (including lighting products and e-cigarette finished goods) based in China are treated as being at a slightly elevated risk compared to our UK based suppliers because of geographic proximity (Supreme representatives have less opportunity for in person engagement and site visits). We have sought to address this risk by engaging with suppliers who are well practiced at obtaining independently accredited third party assessments and reports on their compliance, including in respect of their workforce practises.

We have robust processes to combat modern slavery risks in our own workforce: we carry out right to work checks and adhere to minimum wage obligations.

In accordance with the recommendations of the Home Office statutory guidance, Supreme has taken into account:

• The UN Guiding Principles on Business and Human Rights (UNGPs), https://www.ohchr.org/sites/default/files/documents/publications/guidingprinciplesbusinesshr_en.pdf; and
• The Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Business Conduct (OECD Due Diligence Guidance) https://mneguidelines.oecd.org/due-diligence-guidance-for-responsible-business-conduct.htm and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct https://mneguidelines.oecd.org/mneguidelines/

Supreme seeks to undertake due diligence when considering taking on new key suppliers, and regularly reviews its existing suppliers. Supreme’s due diligence and reviews may include:

• Reviewing the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
• Evaluating the modern slavery and human trafficking risks of each new key supplier;
• Conducting supplier assessments through Supreme’s own staff/third party auditor, which have a greater degree of focus on slavery and human trafficking where general risks are identified; and
• Using resources, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular.

We will continue to review the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains.

During the financial year
The group received no reports or incidents of slavery in its own workforce or its supply chain during the financial year in question.

Future years
Areas identified for potential increased levels of due diligence in future years include:

• Deeper analysis within the supply chain, beyond the group’s direct suppliers i.e. increased assessment and diligence on sub-suppliers, where practicable;
• Wider diligence within the group’s supply chain, beyond the group’s key suppliers, albeit ensuring that a risk-based approach is still maintained to ensure the appropriate prioritisation of resource; and
• Increased third party audits at more regular intervals of existing key suppliers, to ensure maintenance of standards.

Supreme trains and briefs our HR personnel on the applicable policies and procedures relating to recruitment and right to work checks.
The group’s head of procurement also briefs and trains the procurement team on an ongoing basis, on the applicable policies and procedures set out in this statement that are relevant to the department’s supply chain.

These teams have also been provided with an introduction to the training resources published by the Home Office at:
https://www.gov.uk/government/publications/modern-slavery-training-resource-page/modern-slavery-training-resource-page#training-and-awareness-raising-resources

Supreme monitors the following indicators to measure the effectiveness of its actions:

• Any reporting under the Group’s whistleblowing policies; and
• Any breach of Supreme policies by suppliers and any termination of supplier relationships relating to acts or omissions in connection with Supreme’s policies;
• Any reported incidents of modern slavery within our own organisation or through the supply chain.

This statement has been approved by Supreme Imports Ltd’s Board of Directors, who will review and update it annually.

This statement was made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Group’s anti-slavery and human trafficking statement for financial year ending 31 March 2025. It was approved by the Board of Supreme Imports Ltd on the 24 September 2025.

Signed on behalf of the Board by Suzanne Smith – CFO and Director

Schedule – Group Companies (excluding intermediate non-trading holding companies and other non-trading entities)

Clearly Drinks trading (non-holding) companies (acquired June 2024)