Modern Slavery
and Human
Trafficking Statement

2.0 Modern Slavery Policy

Introduction

This statement sets out our practices to combat modern slavery and human trafficking. Modern slavery is a crime and a gross violation of fundamental human rights. It takes various forms, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery.  We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are committed to ensuring that there is transparency in our own business and our supply chains, in our approach to tackling modern slavery, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and, as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children.  We expect our suppliers to hold their own suppliers to the same high standards. 

This statement relates to actions and activities during the financial year January to December.

Being part of the food manufacturing industry, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking, and we continue to take our responsibility very seriously.

Our Business Structure and Supply Chain

This statement covers the activities Zeelandia UK Limited.

Zeelandia UK Limited is a global Company with Zeelandia UK Limited managing its own region in the UK. We have three distribution centres in the UK; these are situated in Colchester, and Wigan.

Zeelandia is a Bakery Ingredient and food Manufacturer. Working with our customers to explore the world of bakery together. We think differently and find inventive ways to create bakery success in the ever-changing food manufacturing industry. We inspire our customers with quality ingredients and innovate exciting new ways to bake, manage and sell.

Once our products have been checked by our quality team the product is then shipped to customers.  We obtain ethically produced raw materials to make up the products.

Countries of Operation and Supply

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Responsibility for our anti-slavery initiatives is as follows:

• Policies: The Human Resources team are responsible for putting in place and reviewing policies; Child Labour Policy and Equality, Diversity, and Inclusion Policy in place to prevent slavery and human trafficking.
• Risk assessments: The Technical department is responsible for risk analysis. Before engaging the services of any supplier or customer we ask them to complete and return an Ethical Questionnaire. The Technical department will then review the questionnaire and determine if they are an ethical Company.
• Investigations/due diligence: The Stakeholder working group is responsible for carrying out investigations and due diligence in relation to known or suspected instances of slavery and human trafficking by our suppliers or customers.

Training: All employees  are provided with training when joining the business, completed by a third-party Company and inhouse training, regarding identifying and preventing modern slavery, as well as annual refresher.

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

Raising Concerns Policy: We encourage all our workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of our Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing box is designed to make it easy for workers to make disclosures, without fear of retaliation.

Company Standards: Our code of conduct makes it clear to employees the actions and behaviour expected of them when representing our Company. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.

Supplier Standards: We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour, via evidence of self-auditing of their suppliers. Suppliers will be required to be members of Sedex or equivalent this is an ongoing process. We work with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of our supplier code of conduct will lead to the termination of the business relationship. 

• Recruitment/Agency Workers Policy: We use 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. Audits are conducted on agencies and their workers.

The Modern Slavery Policy: This policy reflects our commitment to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to ensure that slavery and human trafficking is not taking place anywhere in our supply chains

The Company undertakes due diligence when considering taking on new suppliers and regularly reviews its existing suppliers. Our due diligence and reviews include:

• mapping 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 supplier;
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• in 2026 will start conducting supplier audits which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• creating an annual risk profile for each supplier;
• taking steps to improve substandard suppliers' practices, including providing advice to suppliers through and requiring them to implement action plans;
• participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular;
• using and being Sedex accredited or equivalent, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
• invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously breach our supplier code of conduct, including the termination of the business relationship.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, all staff are able to view the modern slavery statement in the employee policy handbook, and we encourage them to report any concerns to their manager.

Our modern slavery training covers:

• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within our Company;
• what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and "Stronger together" initiative;
• what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
• what steps our Company should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from our supply chains.

Awareness Raising Programme

As well as training staff, we plan to raise awareness of modern slavery issues by putting up posters across our premises and circulating a series of emails to staff. The posters and emails will explain to staff:

• the basic principles of the Modern Slavery Act 2015;
• how employers can identify and prevent slavery and human trafficking;
• what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within our Company; and what external help is available, for example through the Modern Slavery Helpline.

Further Steps

Following a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chains. We will continue to improve our processes and continue to encourage our supply chain and staff to report any concerns they have.

This statement was approved on 24 October 2025 by Emma Lugg, HR Manager and Becky Marsh, Technical Manager and Vaso Koutina, QA Manager. They will review and update this statement annually.

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 31 March 2026.

This commitment is supported by all Senior Managers and Directors, who will provide the resources required to ensure all aspects of this policy is implemented effectively