Modern Slavery & Human Trafficking Statement

At Vintage Vault Trader, we maintain a zero-tolerance stance on modern slavery and are fully committed to operating in a socially responsible and ethical manner. We rigorously comply with EU regulations on modern slavery and human trafficking, embedding these standards throughout our business operations and supply chains.

Organization Structure and Supply Chains

Vintage Vault Trader is a diverse retailer specializing in both new and second-hand jewelry, vintage collectibles, and antiques. Our supply chains include carefully vetted suppliers for jewelry, antiques, packaging, marketing materials, and security systems.

To uphold our values and ensure adherence to EU legislation on modern slavery and human trafficking, we:

• Require all third-party agreements to include strict compliance with relevant anti-slavery and human trafficking legislation within the EU.
• Expect our suppliers to establish effective systems and controls that prevent modern slavery and human trafficking within their operations and supply chains.

Our Policy on Slavery and Human Trafficking

Our Modern Slavery and Human Trafficking Policy reflects Vintage Vault Trader’s commitment to upholding ethical practices and ensuring that no form of modern slavery exists within our operations. This policy includes measures to protect vulnerable customers and provides comprehensive training for new team members as part of their introduction to Vintage Vault Trader. Learn more about our ethical practices.

Due Diligence Processes

In our proactive approach to identifying and managing risks, we:

• Implement a rigorous supplier onboarding process to evaluate and assess all new suppliers for compliance.
• Conduct ongoing supplier reviews to monitor the risk of modern slavery within our supply chain.
• Maintain robust whistleblower protection systems to encourage the reporting of any unethical practices.

Our Compliance team, which includes professionals from Legal, Audit, Human Resources, and Procurement, is responsible for overseeing these processes.

Risk Assessment and Management

Our Compliance and Risk Department, working alongside Finance and Procurement, conducts regular risk assessments of modern slavery across our operations and supply chain. Actions to mitigate any identified risks are implemented, and previous risk assessments are reviewed to measure the effectiveness of these actions. Policies and procedures are updated as necessary to ensure continuous improvement.

Reporting and Key Performance Indicators

If any instances or potential risks of modern slavery are identified:

• In our supply chain, issues are escalated to the Head of Compliance and Risk.
• Within our workforce, concerns are reported to the Head of People or through our whistleblowing process.
• The Head of Compliance and Risk submits all cases to the Compliance and Risk Executive Committee, which reports to the Board if further action is required.

Staff Training

Modern slavery awareness training is a mandatory part of the induction for all new employees at Vintage Vault Trader. Additionally, every team member must complete an annual refresher course to maintain consistent awareness and compliance with our ethical standards.

This statement is made on behalf of Vintage Vault Trader in compliance with EU legislation on modern slavery and human trafficking. It summarizes the actions taken during the fiscal year ending April 30, 2024, and was approved by the Vintage Vault Trader Board on May 8, 2024.