Modern slavery and human trafficking statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “MSA”) and is the public slavery and human trafficking statement of Huggg Limited. 

We are committed to continuously improving our behaviours to combat slavery and human trafficking and are committed to ensuring that slavery and human trafficking are not taking place in our supply chains or in any parts of our business operations. 

Huggg Ltd is private limited is company registration number 09579886 and classified as a small-medium-enterprise.

Our main supply chains are: 

• Voucher and physical gift supply services 
• General professional services
• Software services

Within these categories we believe the following types of goods and services contract are likely to carry the highest risks in relation to modern slavery and human trafficking: 

• Cleaning 
• Retail
• Catering 
• Clothing and promotional goods 
• IT including cloud hosting
• Temporary labour 

Most of these are either not needed or are purchased through managed service providers. 

Huggg highly values its ethical ethos and stance on ensuring there is absolutely no tolerance of modern slavery, human traffic or other forms of labour abuse in our supply chains, customer base or in any other form of commercial interaction we undertake.

Our procurement approach and policy reflect our commitment to act with integrity and ethically in all our business relationships and to implement and enforce effective systems and controls, including in relation to combatting modern slavery and human trafficking in our supply chains. 

We have established a whistleblowing policy designed to provide a process for and protection to employees, contractors and others who wish to raise concerns regarding, amongst other things, our business practices. This policy has been updated to make it consistent with recent legal developments and recommended good practice as well as making express reference to modern slavery in supply chains as an example of a potential concern that may be raised under the policy. 

At Huggg, we are:

• Identifying and training key individuals who have authority to purchase, to ensure this policy is reflected in all purchasing and contracting decisions.
• Implementing a risk-based approach to assess new and existing providers where risks of solution. The repository will include functionality to identify risk types, including modern slavery.
• Requirements being established for appropriate due diligence for new suppliers with whom we contract, which will include modern slavery and trafficking requirements and checks.
• Updating standard terms and conditions of purchasing, which will include provisions concerning compliance with applicable modern slavery laws.
• Developing the policies and supporting practices referred to above.
• Establishing a modern slavery discussion group to help prepare for future and to boost awareness.
• Continuing to identify and assess potential risk areas in our supply chains.
• Continuing to establish how to mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Continuing to monitor potential risk areas in our supply chains and consider proportionate ways to ensure compliance by our suppliers.
• Continuing to commit to the protection of whistle blowers and to encourage the reporting of genuine concerns, including in respect of modern slavery and human trafficking.
• Considering appropriate, effective and proportionate ways of raising meaningful staff awareness including briefings and refresher training.
• Encouraging all team members to stay observant and raise any issues no matter how seemingly small.
• We continue to hire with minimal use of recruitment agencies to ensure all appropriate checks are done.
• Providing input on the above referred to policies which are in development.

This statement was approved by the CEO on 05/11/2025.