Modern Slavery and Human Trafficking Statement

Introduction from the CEO

Modern Slavery continues to be a priority for the PenCarrie Group (together “PenCarrie”) to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain.

We, PenCarrie, are committed to improving our practices to combat slavery and human trafficking in our business and supply chain. We expect our entire supply chain to have a zero-tolerance approach to slavery and human trafficking.

This constitutes PenCarrie’s Modern Slavery statement for the 2024/2025 financial year.

Our Corporate Structure

PenCarrie Holdings Limited is the parent company (which does not trade) and PenCarrie Limited is the main trading entity. The parent company has recently incorporated a new entity in Ireland called PenCarrie Ireland Limited, the purpose of which is to expand distribution into the Republic of Ireland.

PenCarrie Limited and PenCarrie Holdings Limited operate at the following location:

PenCarrie House 
South View Estate 
Willand 
Devon 
EX15 2QW

PenCarrie Ireland Limited operates at the following location:

The Liffey Trust Centre
117-126 Sheriff Street Upper
Dublin 1
Ireland

The vast balance of our operations is in the United Kingdom where we have over 300 employees. PenCarrie Limited has an annual turnover of approximately £115million. PenCarrie Ireland Limited is at its inception phase and therefore has nothing to disclose.

Our Business

Our business is organised into two divisions – third party product distribution and own brand distribution.

PenCarrie 3rd Party Distribution

PenCarrie is a leading business to business wholesale clothing and accessory distributor for decoration and resale. PenCarrie holds 3,600 styles and 85,000 SKUs in stock. Our distribution network serves businesses in every corner of the United Kingdom and Ireland from its Willand-based warehouse.

PenCarrie Own Brand

A subsection of PenCarrie’s business is its own brand development of clothing and accessories for distribution.

Our Supply Chain

PenCarrie recognises that it is crucial for us as an organisation to have oversight of our supply chains so that we can understand the risks of modern slavery along the chain and take action to mitigate against those risks.

We have approximately 25 active Goods For Resale (“GFR”) product suppliers who manage the sourcing and manufacture of promotional and corporate clothing and accessory products. These suppliers are integral to our product distribution whom we have worked with for years and who are expected to provide information on ethical trading and manufacturing processes. We make available all our brands’ manufacturing accreditations and ethical trading policies and statements on our website.

PenCarrie’s purchases from brand suppliers based in the UK, mainland Europe and the USA incorporate the vast majority of our supply chain. The majority of these suppliers manufacture in Bangladesh, Pakistan, India, China and South America. All product items purchased by PenCarrie are for distribution to garment decorators and other on-sellers, primarily in the UK.

We have approximately 570 active suppliers which we categorise as ‘Goods Not For Resale (“GNFR”) suppliers who assist the business through the provision of services and direct goods not directly linked to our product distribution. While these suppliers may present different risk levels, we are committed to extending our modern slavery risk assessments and ethical standards across all supplier categories.

PenCarrie’s Own Brand products are predominantly purchased from India, China and Bangladesh.

For our Labour supply chain we recognise that risk of modern slavery can exist at any stage of our supply chain and in the recruitment and employment of labour. Our commitment is to ensure that all team members working directly for PenCarrie are treated fairly, ethically and with respects for their human rights.

Modern slavery risk management governance

The PenCarrie Board is committed to ensuring all employees are aware of the risks of modern slavery. Although ultimate responsibility for Modern Slavery Act compliance sits with the Board, the Interim People and Culture Director has day-to-day management of modern slavery risk. A new Executive and Senior management structure has been implemented to strengthen lines of communication, risk awareness and accountability of which our Modern Slavery processes benefit. It is also PenCarrie’s approach that all employees are responsible for identifying, assessing and responding to modern slavery risks.

Continuous improvement of operations and supply chain knowledge

We have undertaken, during this financial year, to combat modern slavery in our organisation and supply chain, including:

1. We engaged an ESG consultant who has helped map PenCarrie’s risks and plan an approach to improve our ESG and, particularly, our modern slavery approach. The implementation of the strategy will include strengthening PenCarrie’s corporate governance structure with respect to ESG and setting clear goals and targets for PenCarrie, and its stakeholders, to aspire to;
2. PenCarrie engaged a specialist procurement consultant to strengthen its supplier management processes, supporting enhanced visibility and control across its ‘Goods Not For Resale’ supply chain – an important step in mitigating modern slavery risks and improving ethical compliance;
3. PenCarrie has implemented an Own Brand Code of Conduct to which our suppliers must conform and we also audit Own Brand suppliers to an ISO9001 standard;
4. Rolled out Modern Slavery training to key employees in relevant risk areas;
5. Implemented a new management structure to strengthen the accountability and improve risk management;
6. Implemented a new Modern Slavery policy bringing it into line with our new management structure; and
7. Annually, we receive and review brand supplier ethical trading policies, encouraging our suppliers to continually improve the information supplied, which is then published on our website.

We will continue to improve supplier due diligence process and contractual management processes and embed new processes into everyday use with continuous training.

Due Diligence Processes for Modern Slavery and Human Trafficking

With respect to our Own Brand suppliers we ask all new manufacturing partners to adhere to our Own Brand Code of Conduct before we begin working with them. The Own Brand Code of Conduct sets out the high standards of labour practices and ethical business conduct we expect. This includes, but is not limited to:

• Rejecting the use of any forced or child labour or any workplace discrimination against any worker
• Protecting the rights of all workers to fair and legal working hours, pay, benefits and disciplinary actions
• Ensuring all workers have Freedom of Association and Collective Bargaining rights.

We have the following due diligence processes in place to help make sure we are tackling slavery and human trafficking risks in our third-party distribution supply chains:

• We make written enquiries when considering new apparel product suppliers. We also regularly review our existing product suppliers’ policies on modern slavery and other areas of their operations.
• We place particular reliance on the certifications and trade bodies such as SEDEX, WRAP and Fair Wear Foundation of which many of the brands we represent are members. They are responsible for auditing the brands’ supply chains.
• Each of our brands supplies us with an official Ethical Trading Statement/Policy, which can be found on the individual brand pages on our website.
• We build long-standing relationships with our suppliers, and we make clear our expectations of business behaviour.
• We expect each supplier in the supply chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain. Unfortunately, it’s not practical for us (and every other participant in the chain) to have a direct relationship with all links in the supply chain.
• Additional, often more detailed information is available on the brands’ own websites.

Our policies on Modern slavery and human trafficking

We aim to have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We annually review and update all our policies.

Our Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls aiming to ensure slavery and human trafficking is not taking place in our supply chains. We also have the following policies in place relevant to modern slavery, which we continuously review and update:

• Employee Code of Conduct.
• Own brand Code of Conduct.
• Whistleblowing Policy.
• Modern Slavery Policy.

In addition, we have a robust recruitment policy and process which ensures against the recruitment of child labour. This is supported through a structured application and interview process as well as pre-employment checks.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.

This year, Modern Slavery training has been provided to all key employees who engage with our product and non-product suppliers, recruitment and procurement staff. The content of the training highlighted the various types of modern slavery and employees were tested on their modern slavery knowledge afterwards.

In the next year, we will expand the number of employees who receive training and increase our company-wide awareness-raising campaigns.

Further steps

Following a review of the effectiveness of the actions we have taken this year to combat the risk of slavery and human trafficking in our business and supply chains, we intend to review the following further steps in line with our commitment to continually improve and strengthen our approach year-on-year:

• Implement recommendations from our ESG consultant and strengthen our corporate governance approach.
• Undertake further risk assessment and review of due diligence procedures on our GFR suppliers.

We will engage with various stakeholders to inform both the development and implementation of modern slavery policies.

Board Approval and Publication

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 Dec 2024. It was approved by the board on 19 November 2025.

Signed by:
Mark Campbell,
CEO PenCarrie Limited
Date:19/11/25