Modern Slavery Statement

Modern Slavery Statement


Introduction

This Modern Slavery and Human Trafficking Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (“the Act”) and relates to actions and activities for the financial year ending December 31st 2025.
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Modern slavery is a crime which violates fundamental human rights. Under the Act, the offence encompasses four activities-slavery, servitude, forced or compulsory labour and human trafficking-all of which seek to deprive a person of their liberty for them to be exploited for personal or commercial gain.
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It’s Lolly Limited (“It’s Lolly”, “the Company”, “We” or “Our”) is committed to preventing slavery and human trafficking violations in its operations, its supply chain and its products. We adopt a zero-tolerance policy towards slavery and require our supply chain to comply with our ethical values.
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Organisational Structure

It’s Lolly delivers POS, payment and technology solutions to the hospitality industry. Its clients include corporates, stadia, pubs, restaurants, and coffee shops. The Company has business operations in the United Kingdom and Ireland. It’s Lolly operates in a variety of different sectors, including but not limited to: business and industry, education, bars and clubs, coffee shops, healthcare, sports venues and events/ festivals. The nature of our supply chain is as follows:
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. We work with a number of key direct suppliers who provide us with both goods and services essential to our operations. This includes the procurement of hardware used at both our own premises and at customer sites— such as point-of-sale (POS) systems, terminals, and associated equipment. We also engage with specialist service providers for outsourced business functions, including software development, IT support, cloud infrastructure, logistics, and marketing services.

. Our suppliers are based in various countries, ensuring we have access to the best resources and expertise. Primarily, we source goods from the United Kingdom, however, for specific software and hardware solutions, we extend our reach to international suppliers, mainly in China, Taiwan and Japan.

. We look to prioritise enduring, collaborative and transparent partnerships with our suppliers. Our goal is to build long-term relationships based on trust, quality and innovation, ensuring consistency in service delivery and the ability to scale with our evolving business needs. Where possible, we seek to work with suppliers who align with our values in ethical sourcing and sustainability.


Policies

We operate a number of internal policies to ensure that we are conducting business ethically and transparently. These include the following:

. Recruitment and selection policy: We are committed to ensuring a fair and transparent recruitment process. All vacancies are advertised openly, and all applicants are assessed solely on their ability to carry out the role. We conduct thorough ‘right to work’ checks, ensure all employees are above the legal minimum working age and issue formal contracts of employment to uphold employment rights from the outset.

. Staff code of conduct: We maintain a robust Staff Code of Conduct that affirms our commitment to equal opportunities and diversity. Discrimination, whether direct or indirect, is not tolerated under any circumstances. All employees are expected to promote inclusivity and fairness in their daily work and interactions, ensuring respect for all colleagues, customers and suppliers. We are fully aligned with relevant legislation and codes of practice and take proactive steps to ensure that our internal culture reflects our ethical values.

. Supplier code of conduct: We are committed to working with suppliers who share our values around ethical business practices, human rights, and social responsibility. We expect all our suppliers, contractors, and business partners to operate in compliance with applicable laws and to uphold standards that align with our own, particularly in relation to the prevention of modern slavery, human trafficking, and child or forced labour. Suppliers are expected to provide safe working conditions, treat workers with dignity and respect, pay fair wages, and refrain from any form of exploitation. We reserve the right to review or terminate relationships with any supplier found to be in breach of these principles.

. Whistleblowing Policy: Our whistleblowing policy is a central component underpinning our commitment to preventing modern slavery and human trafficking. The Company encourages all its workers to report any concerns related to conduct that is dangerous, against the law or breaches ethical or professional codes, including any related to modern slavery and human trafficking or child/ forced labour.

. Grievance and Disciplinary Procedure: Employees who believe they have experienced unfair treatment are encouraged to raise concerns through our clearly defined internal channels. Our Disciplinary and Grievance Policy provides a safe and structured process for addressing such issues. This ensures that every employee has a voice and that concerns are handled promptly, fairly, and confidentially.

. Employee Wellbeing: Supporting the well-being of our workforce is a key priority. We provide a range of initiatives aimed at promoting employee wellbeing, including access to programmes such as Health Shield. We believe a supportive and healthy working environment is fundamental to preventing exploitation and fostering long-term satisfaction.

. Communication and awareness: We actively distribute and promote awareness of our internal policies throughout the business. This ensures every member of our team is fully informed of our ethical standards and their responsibilities. We foster a culture of collaboration and accountability, promoting ethical practices at every level of the organisation.

We ensure that we allocate sufficient resources to monitor and enforce these policies on slavery and human trafficking in our business and supply chains.


Due Diligence

As part of our commitment to identifying, monitoring and reducing the risk of modern slavery and human trafficking in our supply chains, It’s Lolly has established a structured due diligence framework. This process forms an integral part of our onboarding process, which is designed to ensure we only work with suppliers that meet our ethical and legal standards:

. Internal supplier review: The initial phase of our onboarding process involves an internal review guided by our Procurement Due Diligence Procedure. This includes the review of any potential red flags related to modern slavery, child labour or other human rights violations. Suppliers are categorised by risk level and ongoing internal reviews are conducted at defined intervals based on this classification. Any significant changes in the supplier’s circumstances may trigger immediate reassessment.

. Supplier self-assessment questionnaires: All new suppliers are required to complete a comprehensive Supplier Questionnaire, which evaluates their policies and controls related to modern slavery, human trafficking and ethical sourcing. This is supported by our Supplier Code of Conduct, which outlines our expectations around fair labour practices, human rights protections and ethical business operations. Periodic reassessments are conducted based on the supplier’s risk profile, ensuring ongoing compliance and accountability.

These due diligence measures are embedded into a broader risk management system that allows us to continuously monitor supplier integrity and ethical performance throughout our contractual relationships. More specifically, they aim to:

. Identify and address potential risks within our business and supply chains.
. Monitor risks to ensure ongoing compliance with ethical standards.
. Minimise the likelihood of slavery and human trafficking occurring within our operations and supply chains.


Risk Management and Compliance
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It’s Lolly regularly evaluates the nature and extent of its exposure to the risks of modern slavery and human trafficking within its operation and supply base. We understand that risk levels can vary by industry, geography and supplier practices, and we take a risk-based approach to managing these challenges through the following measures:

. Supplier Risk Profiling: We maintain and update risk profiles for our suppliers starting with the onboarding process, considering factors such as sector, location, contract value and known risk indicators. This enables us to identify suppliers with a higher likelihood of exposure to modern slavery risks and prioritise them for more rigorous due diligence and oversight.

. Ongoing monitoring and Compliance Checks: The level and frequency of ongoing due diligence are determined by the supplier’s assessed risk level. All suppliers are subject to periodic reviews; however, the scope of these checks varies:
. Low-risk suppliers are required to complete a simplified self-assessment questionnaire annually, with the full Supplier Questionnaire completed every two years.
. High-risk and strategically critical suppliers undergo more rigorous scrutiny, including the completion of the full Supplier Questionnaire on an annual basis.
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This risk-based approach ensures that resources are focused on where the risk of modern slavery and unethical practices is highest, while still maintaining an oversight across the wider supplier base. It also enables us to respond proportionately to emerging risks and any changes in supplier status over time.
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When assessing risks, we consider a range of risk factors, including:
. Country Risk: Suppliers based in regions with weaker labour protections such as China and Taiwan are subject to heightened scrutiny. Country-specific risk profiles are informed by external human rights indices and internal risk reviews.

. Sector Risk: Certain sectors, such as technology and electronics manufacturing, are inherently at higher risk due to the complexity of their supply chains and known exploitation risks.

. Service and Contract Risk: The value, complexity and strategic nature of a contract influence our risk assessment. High-value services are considered higher risks and require more comprehensive due diligence and ongoing monitoring.

. Supplier Relationship Risk: The nature of our engagement with each supplier-whether long-standing or new, direct or via intermediaries-also informs the level of due diligence undertaken.

Our approach to ensuring compliance with ethical standards among our Suppliers involves:

. Ongoing Supplier Communication: We maintain contact with our key suppliers as part of our operations and procurement activities. During these interactions, we reinforce our expectations around legal compliance and ethical business conduct, including our stance on modern slavery.

. Sharing Resources and Guidance: Where relevant, we provide suppliers with access to policies and guidance materials, which includes our Supplier Code of Conduct, to support their understanding of modern slavery risks and responsibilities. We encourage suppliers to take ownership of their own risk management processes.

. Promoting Transparency and Collaboration: We promote open lines of communication with suppliers and encourage them to raise concerns or highlight potential issues. We view supplier feedback as a valuable part of strengthening our due diligence framework and evolving our approach to ethical sourcing.

We do not tolerate slavery or human trafficking in our supply chains. Where there is evidence that a supplier has failed to meet these obligations or has breached our internal policies, we will take appropriate action. This may include requiring prompt remedial steps or, where necessary, terminating the business relationship.


Effectiveness

It’s Lolly is committed to evaluating the impact of our efforts to prevent modern slavery and human trafficking. To support this, we monitor a range of Key Performance Indicators (KPIs) and use the insights from these KPIs to inform process changes, refine our risk assessments and improve our supplier engagement approach. These indicators include:

. Staff Training Feedback: We monitor participation in training sessions and gather informal feedback to assess employee understanding of modern slavery risks and internal procedures. Improvements in awareness and confidence among relevant staff are key indicators of effectiveness.

. Supplier Response Rates and Risk Outcomes: We track the completion rates of supplier questionnaires and monitor the quality of responses received. A high rate of supplier engagement, along with clear and consistent evidence of compliance, indicates that our approach is being understood and taken seriously.

. Risk-Based Review Coverage: We assess the proportion of suppliers reviewed annually in line with their assigned risk category. Ensuring that higher-risk suppliers are being reviewed in full each year, and lower-risk suppliers are reviewed at appropriate intervals, helps us confirm that our risk-based framework is functioning as intended.

. Issue Resolution and Follow-Up: Where concerns are identified, we document the actions taken and monitor their resolution. The timely and effective closure of any issues, and the level of cooperation from suppliers, inform our view of how well our processes are working.

. Process Review and Adaption: We regularly reflect on the outcomes of our due diligence activities to identify gaps, trends, or areas requiring improvement. This helps us evolve our procedures to better detect and prevent modern slavery risks over time.


Training Staff

The Company requires all staff to complete mandatory training supported by refresher courses which we aim to deliver annually to ensure awareness remains current across the Company. This training is a key part of our commitment to ensuring that all employees understand the risks, signs and necessary actions relating to modern slavery in our operations and supply chains. Our training covers a comprehensive range of topics, including:

. Recognising what modern slavery and human trafficking are and the scale of the problem.

. How to identify the signs of modern slavery and human trafficking in both operational and supply chain contexts.

. Understanding the key risks of modern slavery and human trafficking to the Company and its potential implications.

. How to take appropriate action to manage risks and tackle modern slavery and human trafficking.

The training begins during an employee’s initial induction process and is supported by refresher courses that occur every 12 months thereafter to ensure awareness remains current across the Company. Our training strategy reinforces our zero-tolerance approach to modern slavery and ensures that all staff are equipped to act responsibly and effectively in line with our ethical standards.

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Next Steps

In the next financial year, It’s Lolly will continue to strengthen its approach to addressing modern slavery and human trafficking through the following actions:

. We will continue to monitor the effectiveness of our existing KPIs to ensure they provide meaningful insights into the impact of our anti-slavery efforts. Where needed, we will adjust these indicators to better highlight areas for improvement.

. We will continue to integrate modern slavery considerations into our supplier interactions, particularly when engaging with higher-risk suppliers or when changes in risk factors arise.

. We will monitor updates to modern slavery and human rights legislation to ensure ongoing compliance and alignment with best practices. As part of our commercial decision-making process, we will also consider modern slavery risks in the review of new supplier proposals and business cases.


Monitoring and Review

‍We are committed to continuously evaluating and improving our efforts to prevent modern slavery and human trafficking. Our policies and practices are monitored throughout the year to ensure they remain effective, compliant, and aligned with current legislation and industry best practices.

This statement and its associated policies are reviewed annually by our Compliance Officer to assess their effectiveness and identify areas for improvement. As part of the review process, where possible, we consider feedback from internal teams and suppliers to help inform future improvements. Updates and revisions are made as necessary, and the revised statement is shared with employees and published to maintain transparency.

This statement was approved by the Board of Directors of It’s Lolly Limited on 10/06/2025.

Signed on behalf of the Board.

Name: Peter Moore
Title: CEO