MODERN SLAVERY ACT STATEMENT

At PetLab Group Limited (“PetLab Co.”), we are committed to upholding fundamental human rights and believe that all human beings worldwide should be treated with dignity, fairness, and respect. We will only engage businesses, suppliers, direct contractors and organisations who demonstrate a serious commitment to the health and safety of their workers, and who comply with human rights laws. PetLab Co. does not use or condone the use of slave labour or human trafficking and denounces any degrading treatment of individuals or unsafe working conditions.

At PetLab Co., we do things right. We always act with integrity – taking responsibility for our work, caring for our people and staying focused on safety and sustainability. We make investments in people and communities, so we can grow together. Guided by these values, this statement sets out the steps taken by PetLab Co. to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

This statement is made in connection with our 2022 financial year, ending December 31, 2022.

OUR CORPORATE STRUCTURE AND BUSINESS OPERATIONS

PetLab Co. is a U.K. limited liability company with an office located at Dixon House, 1 Lloyds Avenue, London EC3N 3DQ, organised under the laws of England and Wales. Its operations are conducted globally, predominantly in the U.K., EU and US through its subsidiaries, including PetLab Inc. with an office located at 413 W 14th St, FL 2, New York, NY 10014.

  • We market, distribute and mainly sell pet feed, supplements and other pet supplies through online channels and marketplaces.

We currently outsource production to third-party manufacturers, which are responsible for purchasing and maintaining inventory of the company’s products. The majority of our products are delivered to our various distribution hubs or through local fulfilment, where we have outsourced the warehousing and delivery of our products to third-party logistics providers and from which we manage worldwide fulfilment.

OUR POLICIES IN RELATION TO SLAVERY AND HUMAN TRAFFICKING

We have adopted the following policies designed to ensure our commitment to respecting fundamental human rights. PetLab Co. continues to uphold a code of conduct and expects our suppliers, subcontractors, distributors, resellers and other channel partners, consultants, agents and other parties with whom we do business to comply with these best practices and all appropriate standards relating to these matters, which prohibit the use of any form of child or forced labour, slavery, or human trafficking.

  • Code of Business Conduct. PetLab Co. prides itself on developing and maintaining a strong reputation for innovation and integrity. There are many aspects to this effort, but our first priority is ensuring that we each adhere to the highest standards of integrity and conduct; we believe that nothing we do is more important. Our Code of Business Conduct is an essential tool for maintaining that trust by helping to guide our actions and is our guide to how our core values are translated into consistent actions worldwide. As part of our Code of Business Conduct, we prohibit the use of slave labour and human trafficking.
  • Distributor and Other Channel Contracts. Our standard contracts with our channel partners stipulate that compliance with all applicable laws, rules and regulations which thus include those related to human trafficking and worker welfare.

OUR DUE DILIGENCE PROCESSES

Supporting our Code of Business Conduct, Supplier Code of Conduct and other company policies and procedures, we will appropriately conduct ongoing due diligence checks of our business partners based on international indices, media searches and other indicators of supplier risk.

IDENTIFYING, ASSESSING AND MANAGING THE RISKS OF SLAVERY AND HUMAN TRAFFICKING IN OUR BUSINESS AND SUPPLY CHAINS

We outsource manufacturing of our products predominantly to suppliers in the USA, Europe, China and the UK. Local law in these locations may not exist or be as robust as in the U.K. or the U.S.A. to protect populations vulnerable to forced labor or human trafficking risks.

We expect our suppliers to adhere to our policies. In addition, we undertake actions designed to address and mitigate modern slavery risks:

  • We strive to conduct third-party supplier visits. Suppliers must agree to comply with the general and reasonable codes of conduct, including international standards and applicable laws and regulations when they enter into corporate supply agreements or equivalent terms and conditions with us. It is our intention only to do business with companies that share our values around human rights, ethics and environmental responsibility.

TRAINING

We conduct web-based and/or face to face training for employees to emphasize the importance of acting with integrity and in line with our Code of Business Conduct, including the adherence to ethical practices that we require under the Code. Training topics include issues of anti-bribery, compliance with environment and employment laws as well as ethical and fair treatment including provisions such as equal employment, safe working conditions and commitment to fundamental human rights, all designed to reinforce respect for each other as one of our core values.

MONITORING AND MEASURING OUR PERFORMANCE

We continuously monitor our compliance programs for improvements. Were we to find non-compliance with our core values by our suppliers, partners or employees, we would require timely remediation, potentially resulting in re-evaluation and possible termination of the relationship if remediation did not occur.

This statement has been made in accordance with the reporting requirements of Section 54 of the UK Modern Slavery Act 2015 and applies to PetLab Co.