Effective: 1 August 2025
Publication hub: GeiG Legal Hub

1.0 Purpose and Scope

1.1 This statement sets out the actions taken by GeiG to prevent modern slavery and human trafficking in our business and supply chains, in accordance with section 54 of the UK Modern Slavery Act 2015.
1.2 GeiG’s global turnover is expected to meet or exceed the statutory threshold. This is our first statement since GeiG launched in August 2025. We will publish updates at least annually and whenever material changes occur.

2.0 Our organisation and reporting scope

2.1 GeiG operates a technology and commerce platform focused on the design, procurement and sale of computing hardware and accessories, cloud services, warranty and after-sales support, logistics and marketing.
2.2 This statement covers GeiG’s operations and supply chains and applies to any entities, contractors or suppliers operating under GeiG’s control or direction for the purposes of the Act.
2.3 Geography: primary operations in the United Kingdom, with sourcing and manufacturing relationships in Asia and other regions.

3.0 Our policies and standards

3.1 Supplier Code of Conduct. All suppliers must comply with our Supplier Code of Conduct, which prohibits forced, bonded and child labour, requires lawful wages and working hours, and mandates safe and humane working conditions. The Code must be flowed down through the supply chain.
3.2 Related policies. Our approach is supported by policies on Whistleblowing, Anti-Bribery & Corruption, Ethical Recruitment & Agency Workers, Ethical Procurement, and Supply-Chain Due Diligence.
3.3 Contractual controls. Supplier contracts include modern-slavery representations and warranties, audit rights, remediation obligations, and recruiter-fee clauses requiring employer-pays remediation where recruitment fees are identified.
3.4 Standards alignment. Supplier expectations align with the ILO Core Conventions and the Ethical Trading Initiative (ETI) Base Code.

4.0 Risk landscape and prioritisation

4.1 Higher-risk categories in our sector include electronic components and minerals (including conflict minerals), assembly and manufacturing, warehousing and logistics, and contingent or agency labour.
4.2 We apply a risk-based methodology considering country risk, commodity risk, labour models, supplier size, and audit history to prioritise due diligence and controls.

5.0 Due diligence and controls

5.1 Onboarding. New suppliers undergo due-diligence questionnaires, sanctions and ESG screening, verification of credentials, and acceptance of our Supplier Code and contractual clauses.
5.2 Independent audits. Higher-risk suppliers must provide independent third-party social audit reports (for example SEDEX/SMETA, RBA or equivalent) or accept GeiG-commissioned audits. Audit frequency is at least annually for high-risk suppliers and every 24 months for medium-risk suppliers.
5.3 Monitoring. We conduct scheduled and trigger-based reviews, including unannounced visits where credible indicators exist. Worker interviews and direct observation are core features.
5.4 Recruitment and agency labour. Suppliers must demonstrate ethical recruitment practices. Any recruitment fees identified must be repaid to workers under an employer-pays remediation model.
5.5 Records. Due-diligence and audit records are retained for at least six years.

6.0 Remediation and escalation

6.1 Where non-conformance is identified, suppliers must implement a Corrective Action Plan (CAP) with time-bound milestones and independent verification. High-risk findings normally require verification within 90 days.
6.2 Where remediation fails or harm is substantiated, GeiG may suspend orders, place suppliers on hold, or terminate contracts, using controlled exit plans where abrupt termination could harm workers.
6.3 Victim-centred remediation. Remedies prioritise workers, including repayment of recruitment fees, continued pay during transition where practicable, access to medical or legal support, and secure relocation or repatriation where required.
6.4 Serious incidents or suspected criminality are reported to competent authorities, and GeiG cooperates fully.

7.0 Worker voice, grievance channels and non-retaliation

7.1 We provide multiple grievance channels, including:
(a) web chat and email (support@geig.co.uk) with anonymity options;
(b) supplier-managed confidential reporting in local languages; and
(c) independent third-party hotlines at higher-risk sites where appropriate.
7.2 Suppliers must inform workers of these channels and guarantee non-retaliation. Evidence of worker-voice mechanisms is reviewed during audits.

8.0 Training and capacity building

8.1 Internal training. Procurement, HR, operations and leadership receive modern-slavery training every six months, covering red flags, interviews, grievance handling and escalation.
8.2 Supplier training. Higher-risk suppliers must provide annual training to supervisors and HR staff and supply evidence of completion.

9.0 Effectiveness, KPIs and transparency

9.1 We will publish baseline values and progress in the next annual statement. Target KPIs include:

• ≥95% of active suppliers signed to the Supplier Code of Conduct;
• ≥90% of higher-risk suppliers audited in the audit cycle;
• ≥85% of CAPs closed on time (median closure ≤ 90 days);
• 100% training completion for in-scope staff within each 6-month cycle;
• median grievance response ≤ 5 business days; ≥95% grievance resolution within 30 days.
  9.2 Accountability for KPI delivery sits with Procurement and Supply-Chain Due-Diligence, with annual reporting to the Board.

10.0 Governance and accountability

10.1 Operational responsibility rests with the Supply-Chain Due-Diligence and Procurement teams. Oversight is provided by senior leadership and the Board.
10.2 Material risks or failures of remediation are escalated for decision on suspension, termination or disclosure.
10.3 The Board reviews modern-slavery risks and effectiveness annually.

11.0 Next steps (FY 2025/26 roadmap)

11.1 Complete baseline risk mapping of tier-1 suppliers and extend mapping to critical tier-2 suppliers where feasible.
11.2 Publish the Supplier Code of Conduct and due-diligence criteria on the GeiG Legal Hub.
11.3 Expand worker-voice mechanisms at higher-risk sites.
11.4 Integrate modern-slavery checks into contract renewals and purchase-order gating.

12.0 Publication and accessibility

12.1 Period covered: 1 August 2025 – 31 July 2026. Updates will be published within six months of period end.
12.2 This statement is published on the GeiG Legal Hub with a prominent link on GeiG.co.uk and is available in large-print or plain-text on request.

13.0 Contacts and remedies for workers

13.1 Public contact for concerns: support@geig.co.uk and 24/7 web chat on GeiG.co.uk. Anonymous reports are accepted.
13.2 Postal contact: GeiG, Riverside Business Centre, Fort Road, Tilbury, Essex, RM18 7ND, United Kingdom.

14.0 Approval and sign-off

14.1 This statement was approved by the GeiG Board on 1 August 2025.
14.2 Signed by: Keith Charles, Director.
14.3 Date of signature: 1 August 2025.

End of Modern Slavery & Human Trafficking Statement (v1.2)