Modern Slavery Statement

This statement is made pursuant to section 54 of the Modern Slavery Act 2015.

It sets out the steps that Bubblegum and its UK affiliates has undertaken – and is continuing to take – to try to prevent modern slavery or human trafficking from taking place within our business or supply chain.

We are committed to acting ethically and with integrity in all our business relationships and this includes taking steps to work towards the removal of slavery and human trafficking from our business and our supply chain. We are implementing effective systems and controls to try and make sure that modern slavery does not take place anywhere within our business. We are a UK based business and we are aware that modern slavery exists even in the UK, so we cannot be complacent when it comes to these issues.

We are also committed to ensuring there is 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 (the “Act”).

Significant risks in our business

We are aware that the following areas of our supply chain and business are those where there is a risk of modern slavery occurring:

1. Casual staff: We make use of casual staff and stay vigilant for the signs that other work they do could fall under the definition of modern slavery.

2. Operational and marketing consumables: These items are often manufactured in the Far East and in areas of Europe where slavery has been identified in the past.

Viewing our supply chain as a whole, the key suppliers that we consider represent a risk of modern slavery and/or human trafficking are found in the Far East and the UK.

Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. Anti-slavery policy: This policy sets out our expectations of all employees and any others who work in our business in relation to slavery and human trafficking issues, including providing guidance on recognising modern slavery, and how employees should raise any concerns they have. This policy can be found on the internal document library in the modern slavery section

2. Whistleblowing policy: This sets out the whistle blowing policy, so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals. This policy can be found in our internal training which employees complete when joining the company.

3. Supplier Code of Conduct: This code sets out the minimum standard we expect all our suppliers to take to work towards eradicating slavery and human trafficking in their business and supply chain.

Our suppliers

Our supply chain is varied, but our key suppliers are those from whom we purchase our decorations and consumables. Our supply chain is based globally and our suppliers themselves source globally.

Our Supplier Code of Conduct forms part of our contract with our suppliers and they are required to confirm that no part of their business operations contradicts this policy. Suppliers are also required to obtain confirmation from their own suppliers and subcontractors that they comply with the Supplier Code of Conduct.

The Supplier Code of Conduct requires suppliers to confirm the following relating to their business and supply chain:

1. wages paid to workers are fair;

2. working hours and annual leave comply with national laws and industry standards;

3. no child labour is used;

4. no forced, bonded, compulsory labour or servitude, or any form of human trafficking is practiced;

5. abuse of workers is not tolerated;

6. a secure, safe and healthy working environment is provided;

7. freedom of association and collective bargaining is respected; and

8. local laws relating to discrimination are complied with.

Next Steps

Looking forward, we will continue working with our suppliers to promote awareness of slavery and human trafficking.