Human Rights and Labour Policy

At Smudge & Friends Petcare Limited t/a Scrumbles, our commitment to human rights and fair labour practices is an important part of our responsibility as an ethical pet food company. We aim to have a positive and sustainable impact on our employees, communities, supply chain and the wider world.

We recognise our responsibility to respect fundamental human rights, promote fair labour practices and support the ethical treatment of workers throughout our operations and supply chain.

This Human Rights and Labour Policy outlines our commitments and guides our actions as a responsible pet food company headquartered in the United Kingdom and operating internationally. The principles in this policy apply to all employees, management and contract workers of any entity within the Smudge & Friends Petcare Limited Group, irrespective of the country in which they work, alongside all applicable local employment and labour laws.

1. Respect for Human Rights

We are committed to respecting and promoting the fundamental human rights of individuals involved in or affected by our business operations, including our employees, workers, suppliers and other business partners.

Our approach is informed by internationally recognised human rights principles and standards, including:

• the Universal Declaration of Human Rights;

• the International Labour Organization (ILO) Core Conventions; and

• the UN Guiding Principles on Business and Human Rights.

We comply with applicable employment and labour laws in the countries in which we operate and seek to apply the principles set out in this policy consistently across our operations and supply chain.

2. Fair Labour Practices

We believe everyone should be treated with dignity, fairness and respect. We are committed to providing a safe, healthy and inclusive working environment and to promoting fair labour practices throughout our operations.

Non-Discrimination: We prohibit unlawful discrimination in all its forms, including on the basis of race, colour, nationality, ethnic or social origin, sex, gender, gender identity, religion or belief, sexual orientation, age, disability or any other characteristic protected by applicable law. This applies throughout employment, including recruitment, promotion, compensation and treatment at work.

Freedom of Association: We respect employees' rights to join or form associations or trade unions of their choice and to participate in collective bargaining, in accordance with applicable law.

Child Labour: We prohibit child labour within our operations and supply chain and comply with applicable laws and international standards concerning minimum working age, including the relevant ILO Conventions.

Forced Labour and Modern Slavery: We prohibit all forms of forced, bonded or compulsory labour, modern slavery and human trafficking within our operations and supply chain. Workers must enter into employment voluntarily and be free to leave employment in accordance with applicable law.

Working Hours, Wages and Benefits: We comply with applicable laws and regulations relating to working hours, minimum wages, overtime, rest periods and employee benefits. We aim to provide fair and competitive compensation and working conditions.

Health and Safety: We are committed to providing a safe and healthy working environment and complying with applicable health and safety laws and regulations. We seek to identify and manage workplace risks and promote practices that protect the health, safety and wellbeing of workers.

3. Responsibility

At Board level, the CEO has overall responsibility for this policy, supported by senior leadership to ensure its effective implementation and oversight.

Managers are responsible for promoting respect for human rights within their areas of responsibility and ensuring their direct reports receive appropriate information and training.

All employees and workers are responsible for ensuring their own actions respect the rights of others. Employees are encouraged to raise concerns about potential breaches of this policy through available reporting channels. Concerns may be raised without fear of retaliation for reporting them in good faith.

4. Our Supply Chain

We extend our commitment to human rights and fair labour practices to our suppliers and business partners. We expect suppliers to respect internationally recognised human rights and comply with applicable employment and labour laws within their own operations and supply chains.

We take a proportionate, risk-based approach to identifying, assessing and addressing potential human rights and labour risks within our supply chain.

Supplier Code of Conduct: We expect our suppliers to adhere to our Supplier Code of Conduct, which sets out the ethical, social and environmental standards we expect of them. We also expect suppliers to maintain appropriate policies and controls within their own operations and supply chains.

Due Diligence: We conduct proportionate and risk-based due diligence to identify, prevent and mitigate human rights and labour risks where appropriate. Where issues are identified, we seek to work with suppliers to understand the circumstances and implement appropriate corrective actions. We reserve the right to suspend or terminate relationships in cases of serious or persistent non-compliance.

Remediation: Where we identify that Scrumbles has caused or contributed to an adverse human rights impact, we are committed to providing or cooperating in appropriate remediation. Where an impact is directly linked to our operations, products or services through a business relationship, we will seek to use our influence appropriately to encourage prevention, mitigation and remediation.

5. Raising Concerns

We encourage employees, workers, suppliers and other relevant stakeholders to raise concerns where they believe this policy may have been breached or where there may be a risk to human rights or fair labour practices.

We are committed to considering concerns appropriately and do not tolerate retaliation against anyone who raises a genuine concern in good faith.

6. Communication and Training

We communicate this Human Rights and Labour Policy to relevant employees, workers and stakeholders and provide appropriate information or training to support awareness and understanding of its principles.

We also communicate our expectations to relevant suppliers and business partners through our Supplier Code of Conduct and associated supplier management processes.

7. Continuous Improvement

We recognise that respecting human rights is an ongoing responsibility. We are committed to continually improving our approach to human rights and fair labour practices and will periodically review this policy, our procedures and our practices to reflect changes in our business, emerging best practice and applicable legal requirements.

This policy applies across Scrumbles' UK and international operations and will be reviewed and updated as appropriate.