Introduction

Humfree Ltd is committed to conducting business ethically and with integrity. We have zero tolerance for modern slavery, human trafficking, forced labour and unlawful child labour in any part of our business or supply chains.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and outlines the steps taken during the financial year to prevent modern slavery within our operations and supply chain.

Our business and structure

Humfree Ltd operates in the mobility sector, supplying products and related services within the United Kingdom. Distribution, delivery and servicing activities are fulfilled through a combination of in-house logistics operations and third-party logistics partners based in the UK.

Where products, components or services are sourced from external suppliers, we recognise our responsibility to assess and manage potential risks within those supply chains.

Our policies

We are committed to maintaining high standards of ethical conduct and have implemented the following policies to support this commitment:

• Corporate Social Responsibility Policy
• Supplier Code of Conduct
• Employee Code of Conduct

Our Supplier Code of Conduct prohibits the use of forced, bonded (included debt-bonded) or indentured labour, involuntary prison labour, slavery, trafficking of persons and unlawful child labour. All suppliers are expected to comply with applicable laws and to uphold these standards within their own supply chains.

Due diligence and supplier management

We adopt a proportionate, risk-based approach to managing modern slavery risks. Suppliers are required to confirm compliance with our Supplier Code of Conduct as a condition of doing business with us. Compliance is considered when awarding or renewing contracts.

Where appropriate, we reserve the right to request further information or assurance regarding labour standards and supply chain practices. Failure to meet our required standards may result in corrective action or termination of the business relationship in accordance with contractual rights.

Risk assessment

We recognise that modern slavery risks can arise in both direct operations and extended supply chains. While our logistics partners are UK-based, we remain alert to potential risks in product sourcing and third-party relationships.

Risk is assessed based on factors such as geography, industry sector and the nature of the services or goods provided. This enables us to focus attention where the potential exposure may be greater.

Training and awareness

All employees are expected to uphold our ethical standards. Upon joining the business, employees are required to read and acknowledge our Corporate Social Responsibility Policy and Code of Conduct.

Relevant employees involved in procurement and supplier management are required to familiarise themselves with the Supplier Code of Conduct and to remain alert to indicators of modern slavery or unethical labour practices.

Reporting concerns

We expect staff at all levels to report any concerns regarding potential breaches of our policies. Management is responsible for investigating concerns appropriately and taking action where required.

Measuring effectiveness

We review our policies and supplier standards annually to ensure they remain effective and proportionate. Supplier compliance confirmations and internal policy acknowledgements form part of our ongoing monitoring framework.

We remain committed to strengthening our processes and improving transparency across our operations and supply chains.

Approval

This statement has been approved by the Board of Directors of Humfree Ltd and signed on its behalf by:

Tom Powell
Co-founder and Managing Director

Date: 27.02.2026