MODERN SLAVERY ACT

TRANSPARENCY STATEMENT

This statement has been published with accordance with the Modern Slavery Act
2015 (UK) which requires businesses to disclose publicly what steps they are
taking to tackle modern slavery each year.

OUR APPROACH

Neo Direct Ltd sources, develops and distributes own label consumer goods
direct from manufacturing origins in EU and global sources. We trade through
online channels direct to customers through various third party and own
platforms and our products are available to buy in the UK & EU.

We are committed to eradicating modern slavery – we will not tolerate or
knowingly work with any suppliers domestic or international that are involved
with any form of slavery including, but not limited to human trafficking and
exploitation in addition to our own code of conduct.

NEO DIRECT COLLEAGUES

All new colleagues are required to read and accept the policies outlined in the
Company Handbook. The Handbook provides our colleagues details of our key
policies including Health & Safety, Code of Conduct, Pay & Benefits, Recruitment
& Equal Opportunities, Bullying, Harassment & Anti-Bribery and Whistleblowing.

Our Recruitment process is to promote from within and carry out direct
recruitment wherever possible. Checks are carried out as part of this recruitment
process including ensuring all perspective employees have the correct right to
work documents, checking and making a copy of Passport as well as checking
references from previous employment.

When paying wages this is only paid direct to bank accounts and we ensure all
employees have an authentic Home Address and National Insurance Number.

When we do work with temporary labour agencies, we only work with 2 long-term
partners who have been briefed on the standards that we expect of them, whilst
we review their own statements and policies to meet these high standards.

NEO DIRECT LTD GLOBAL SUPPLY CHAIN

As we find ourselves in the second-year post-pandemic, regular supplier trips
that began in 2023 continue this year. Trips to our factories and industry fairs
have already been scheduled with members of our QA, Buying and senior
management teams with the intent of fostering close working relationships and a
deeper understanding of our products and suppliers.
All new suppliers are expected to provide their third-party audits which are
reviewed by our QA Department prior to approval for partnership, and 2024 sees
the introduction of our factory score cards which takes into account supply chain
transparency. This will help to maintain and elevate our suppliers, ensuring a
consistent approach across our selected partnerships and their 3rd party
vendors. This is our next step in formative action for the continuous improvement
of our anti-slavery policy.
Management of our existing supply chain is done via consistent review of ethical
audits, yearly resigning of codes of conduct, and close working relations with our
trusted overseas partners.

Dated: 3rd February 2024

Signed:
Michael Powell, CEO