Modern Slavery Policy

1. Modern Slavery Act 2015

1. 1. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking. In whatever form, it involves the deprivation of one person's liberty by another to exploit them for personal or commercial gain.
   2. Bonnington Plastics Limited (“BPL”) has a number of subsidiary undertakings. The current subsidiarys are WIDO Limited, Big Fish Hong Kong Trading Limited and Big Fish Ningbo Trading Co. (“Group”).
   3. Modern Slavery has no place within the Group or its supply chain.

1. 4. The Group is committed to acting ethically and with integrity in all its business relationships and to ensuring that there is no modern slavery in its supply chain or in any part of its business.
   5. The United Kingdom (“UK”) Modern Slavery Act 2015, section 54 requires every organisation carrying on business in the UK with an annual turnover greater than £36m, to produce and publish a modern slavery and human trafficking statement (“Statement”) each financial year. The Statement is intended to set out the steps the organisation is taking during the relevant financial year to ensure slavery and human trafficking are not taking place within any part of its supply chain or any part of its business.
   6. The Group does not yet have an annual turnover greater than £36 million and there is no obligation upon it to produce a Statement. The UK Government, however, encourages all UK businesses, even those who have no obligation to do so, to produce a Statement, to be transparent about their recruitment practices, policies and procedures in relation to modern slavery and to take steps that are consistent and proportionate with its sector, size and operational reach to combat modern slavery.
   7. The Group has produced this Statement voluntarily as an expression of its commitment to the eradication of modern slavery in any part of its supply chain and every part of its business.
2. The Group’s Business

2. 1. The Group is a UK based importer and wholesaler of gardening and catering, electrical, and seasonal products amongst others. It distributes products, predominantly within the UK and the Republic of Ireland, under various brands.
   2. The Group does not manufacture goods. The products it sells are manufactured mainly in the Peoples Republic of China (“PRC”) and imported into the UK through Big Fish Hong Kong Trading Limited (based in Hong Kong) and Big Fish Ningbo Trading Co. (based in the PRC).
   3. The products sold by the Group are imported and distributed throughout the UK and the Republic of Ireland.
3. UK Supply Chain

3. 1. The Group considers its UK supply chain to be at low risk from modern slavery although it regularly monitors its supply chain for the emergence of higher levels of risk. Within the UK, the supply chain consists mainly of transport, IT support, temporary and permanent recruitment, insurance, legal, accountancy and cleaning service providers.
   2. The Group utilises a small number of reputable service suppliers with whom it has close trading relationships and chooses to trade only with suppliers who have a high reputation for integrity.
4. Non-UK Supply Chain

1. 1. Outside the UK, the Group’s supply chain consists mainly of manufacturing and transport service providers within the PRC. The Group has identified a vulnerability to modern slavery in its PRC supply chain and is implementing a training programme for both its UK and PRC based buying team and senior management to help identify and understand the signs of modern slavery.
   2. The Group intends to start regular visits to its PRC suppliers’ factories to establish the extent, if any, that modern slavery exists in those factories once COVID restrictions allow. The visit reports will be monitored and reviewed in the UK
      3. Should the visits identify areas of risk, further policies will be introduced to tackle those risks