MODERN SLAVERY STATEMENT

Effective Date: 9 August 2025

NON-NEGOTIABLE STANDARDS: AURICLE does not tolerate modern slavery, forced labour, child labour, or human trafficking. These requirements are mandatory for our suppliers and contractors.

If you have concerns or information related to modern slavery connected to our business or supply chain, email info@auricle.co.uk. We aim to respond within 5 business days.

1. WHO WE ARE AND SCOPE

This statement covers auricle.co.uk, auriclejewelry.com, and our Shopify Checkout (hosted on Shopify). It applies to our B2B wholesale operations and to suppliers and contractors who provide goods or services to AURICLE.

Website use is governed by our TERMS OF SERVICE. Company details are on COMPANY INFORMATION.

2. APPLICABILITY UNDER LAW

We publish this statement voluntarily in line with the intent of the UK Modern Slavery Act 2015. If and when AURICLE meets the statutory threshold requiring a statement under section 54, we will treat this document as our formal annual statement under that Act and update it accordingly.

3. OUR BUSINESS AND SUPPLY CHAIN

We operate a B2B wholesale jewellery brand supplying professional studios and jewellers. Our supply chain includes materials, manufacturing, finishing, packaging, shipping (including Royal Mail and DHL), and professional services.

4. POLICIES AND EXPECTATIONS

Zero tolerance of forced labour, child labour, human trafficking, debt bondage, and exploitative working conditions.
Legal compliance with applicable labour, health & safety, and immigration laws.
Transparency on site locations, subcontracting, and key production steps.
Right to audit / verify reasonable information relating to labour practices where risk is identified.
Mandatory cooperation with investigations and corrective actions.

These requirements form part of our supplier onboarding and ongoing relationship management.

5. DUE DILIGENCE

We apply proportionate checks during onboarding and periodically thereafter, including:

Supplier questionnaires covering labour practices and site locations.
Reasonable verification requests (e.g., independent audit summaries, certifications, or policy statements where available).
Contractual clauses requiring compliance with anti-slavery laws and our standards.
Risk-based follow-up where geography, sector, or product category indicates higher risk.

6. RISK ASSESSMENT

We review risk with reference to:

Geography (country risk indices and known sector risks).
Process (outsourced manufacturing, finishing, or subcontracting).
Signals (unusual lead times, pricing pressure inconsistent with legal wage costs, restrictions on worker movement).

Where elevated risk is identified, we escalate due diligence and/or require corrective actions.

7. MONITORING, NON-COMPLIANCE & REMEDIATION

We investigate credible allegations in good faith, request evidence, and agree a Corrective Action Plan with timelines where issues are identified.
For serious or unremedied breaches, we may suspend orders or terminate the relationship.
We keep appropriate records of investigations and outcomes.

8. TRAINING & AWARENESS

Relevant staff (buying, operations, and leadership) receive periodic guidance on:

Recognising red flags for modern slavery and trafficking.
Our reporting channels and escalation steps.
How contractual controls and supplier engagement reduce risk.

9. REPORTING CONCERNS (WHISTLEBLOWING)

Anyone can report concerns to info@auricle.co.uk. We will treat reports sensitively, share information only on a need-to-know basis, and will not tolerate retaliation for good-faith reporting.

10. METRICS WE TRACK

We monitor:

Number of supplier risk reviews conducted.
Corrective Action Plans raised and closed.
Issues escalated to suspension/termination.
Staff training completion in relevant teams.

11. REVIEW & PUBLICATION

We review this statement annually and whenever material changes occur in our business or supply chain. The most recent version is published at /modern-slavery-statement.

12. APPROVAL

If required by law (e.g., upon meeting statutory thresholds), this statement will be approved by the Board and signed by an authorised director for the relevant financial year.

Version: 09.08.2025