Modern Slavery Act Statement 2026

The Cotswold Company takes all forms of slavery and human trafficking seriously. This is our seventh Modern Slavery Statement, published in accordance with Section 54 of the Modern Slavery Act 2015.

We continue to draw on the Ethical Trading Initiative Base Code and the International Labour Organisation’s Forced Labour Protocol as guiding frameworks, and we remain committed to preventing any form of modern slavery within our business and throughout our supply chain.

The Cotswold Company is a multi-channel furniture and homewares brand with 19 retail locations across the UK, multiple logistics centres in the Midlands, and offices in Norwich, China and Vietnam. Our supply chain, showroom network and logistics footprint continue to grow.

The Board of Directors holds overall responsibility for compliance with this statement. Day-to-day responsibility sits with the Chief Operating Officer. Senior managers across our warehouse, retail, sourcing and people functions are responsible for ensuring compliance within their teams.

We work with suppliers across the world who share our brand values. We recognise that the scope of our supply chain carries inherent risk of exposure to modern slavery, and we focus our efforts on identifying and addressing those risks systematically.

The right to work is verified for all employees of The Cotswold Company worldwide. Our Employee Handbook sets out clear policies on health and safety, diversity and non-discrimination, with established procedures for reporting concerns.

We don’t just ensure these requirements are made in-house though, we also take steps to guarantee our supply chain meets these important requirements too.

Supplier Quality Manual

All suppliers are required to acknowledge and comply with The Cotswold Company Supplier Quality Manual as a condition of doing business with us. Section 5 of the Manual sets out our minimum requirements on responsible sourcing, human rights and working conditions, drawing directly on the ETI Base Code. Where our requirements and local legislation differ, the standard that offers the greater protection to workers applies. Failure to meet these requirements constitutes grounds for termination of the business relationship.

Supplier Ethical Data Exchange (SEDEX)

All Tier 1 direct suppliers are required to register with SEDEX and complete the self-assessment questionnaire. As part of our ongoing programme of compliance review, we are currently auditing the status of all Tier 1 SEDEX registrations and questionnaire currency. This work, led by our Ethical Compliance Officer in Vietnam, is identifying gaps which are being addressed directly with the relevant suppliers.

SMETA Audits

We require all Tier 1 suppliers to hold a current, independent SMETA audit — defined as within the last two years with all critical and high-level findings closed. A structured review of audit currency is currently underway. Where audits are found to be lapsed or missing, suppliers have been notified and remediation is being tracked against our KPI targets.

We continue to progress improvements to visibility and minimise the risks associated to modern slavery within any supply chain that we have exposure to.

Ethical Compliance - Vietnam Team

In the past year we have established a dedicated Ethical Compliance Officer role within our Vietnam team. This role is responsible for the management of all Tier 1 direct supplier SMETA audits, ensuring they are current and that critical and high-level findings are resolved in accordance with our KPIs:

• Tier 1 direct supplier audits less than two years old

• Percentage of Tier 1 direct suppliers rated low or medium risk (minor or zero outstanding issues)

These KPIs are reported internally and provide a structured basis for prioritising supplier engagement and corrective action.

Supplier Visits

Our UK-based management teams make regular visits to Tier 1 supplier sites, supplemented by our locally based teams in China and Vietnam who maintain frequent on-site presence. During visits, spot reviews of employee records, timesheets and working facilities are conducted.

Due Diligence

All new suppliers complete a questionnaire to identify potential risk areas before a full SMETA audit is required. Audit findings are reviewed on the SEDEX platform alongside country and industry risk assessments to inform ongoing supplier risk ratings.

Employee Training

Employees directly involved in supply chain management receive training on identifying and addressing potential breaches of our responsible sourcing requirements, with a specific focus on recognising indicators of modern slavery.

We will continue to develop our audit management processes, advance Tier 2 supplier coverage, and use the data generated by our SMETA review programme to direct resources to the highest-risk relationships. We will publish our progress against our ethical compliance KPIs in subsequent statements.

This statement has been approved by the Board of Directors and will be reviewed and republished annually.

Ralph Tucker
Chief Executive Officer, The Cotswold Company Ltd
August 2026