Modern Slavery Statement
Last updated: 28 August 2025
Policy Statement
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, all of which involve the deprivation of a person’s liberty to exploit them for personal or commercial gain. The Bluum Group has a zero-tolerance approach to modern slavery, and is committed to acting ethically and with integrity in all business dealings and relationships, as well as implementing effective systems and controls to ensure modern slavery does not take place anywhere in our own business or our supply chains.
1.2 We are also committed to ensuring transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, 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. 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, and we expect that our suppliers will hold their own suppliers to the same high standards.
1.3 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
1.4 This policy does not form part of any employee’s contract of employment, and we may amend it at any time.
Responsibility for this Policy
2.1 The board of directors at The Bluum Group has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
2.2 The designated Compliance Manager is responsible for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they effectively counter modern slavery.
2.3 Management at all levels is responsible for ensuring their teams understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
2.4 Staff are encouraged to comment on this policy and suggest ways to improve it. Comments, suggestions, and queries should be addressed to the Compliance Manager.
Compliance with the Policy
3.1 All staff and those working on our behalf must read, understand, and comply with this policy.
3.2 The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. Staff must avoid any activity that might lead to or suggest a breach of this policy.
3.3 Staff must notify their manager or the Compliance Manager as soon as possible if they believe or suspect that a potential conflict with this policy has occurred or may occur in the future. Reports may also be made via our Whistleblowing procedures.
3.4 Staff are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains or any supplier tier at the earliest possible stage.
3.5 If a breach or potential breach is suspected, it must be reported immediately as outlined above. Where appropriate, and with the welfare and safety of local workers as a priority, we may give support and guidance to suppliers to help them address coercive or exploitative work practices in their businesses and supply chains.
3.6 If unsure whether a particular act, treatment of workers, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, staff should raise it with their manager.
3.7 The Bluum Group encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. No one will suffer any detrimental treatment as a result of reporting in good faith their suspicion of modern slavery in any part of our business or supply chains. If an individual believes that they have suffered any such treatment, they should inform the Compliance Manager immediately and, if unresolved, raise it formally under our Grievance Procedure.
Communication and Awareness of the Policy
4.1 Training on this policy, and on the risks our business faces from modern slavery in its supply chains, forms part of the induction process for all staff and will be provided regularly as necessary.
4.2 Our commitment to addressing the issue of modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Breaches of the Policy
5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
5.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
This statement is made according to section 54(1) of the Modern Slavery Act 2015 and constitutes The Bluum Group’s slavery and human trafficking statement for the financial year ending 31st May 2026.
This statement has been approved by the board of directors of The Bluum Group on 28 August 2025.
Signed:
Dan Keith & Bartosz Bergandy
Co-Founders, The Bluum Group
28 August 2025