1. Organisational Structure, Business and Supply Chains

Parent Company and Trading Entities

Biodeb Group Ltd is the parent company for two distinct trading entities, each with its own specialist focus. Both entities operate under the overarching governance of the Biodeb Group Ltd Board, with our director, a scientist, providing technical oversight across all operations.

Radiant Glow Botanicals

The Radiant Glow Botanicals brand was originally established in 1994 as own brand and supplier of skin care products, wigs, human and synthetic hair, and associated accessories. In 2013, the brand merged with Biodeb Group Ltd, bringing together decades of expertise in Afro-Caribbean personal care under a single corporate structure. Today, Radiant Glow Botanicals operates as the consumer facing brand of Biodeb Group Ltd, supplying products to customers in the United Kingdom, the European Union, Africa, and other global markets through our distributorship network and online platforms.

Biodeb Consulting Ltd

Biodeb Consulting Ltd is the advisory and technical consultancy arm of Biodeb Group Ltd. The subsidiary provides expert guidance on business development, organic skin care formulation, manufacturing processes, hair pieces, wigs, and accessories. Biodeb Consulting Ltd draws directly on the scientific expertise of our director and serves as a trusted advisor to manufacturers, distributors, and other stakeholders in the personal care and consumer industry. Further information about the consultancy's work can be found at www.biodebconsulting.co.uk.

Our Director – Scientific Leadership

Our director, with specialist expertise in organic skin care formulation and manufacturing, including hair pieces, wigs, and accessories. As a recognised speaker in the field, the director provides technical leadership across both subsidiaries, ensuring that product development, quality assurance, and manufacturing oversight are grounded in rigorous scientific principles. This scientific foundation is particularly valuable for Afro-Caribbean skin and hair care, where technical knowledge of formulation and ingredient science is essential.

Our Business Operations and History

Our business originated in 1994 as a buyer and supplier of human and synthetic hair, wigs, skin and hair care products, and all associated accessories. This was complemented by a hairdressing salon and beauty spa in East London, specialising in braiding, hair maintenance, hair extensions, wigs, and aftercare.

As technical experts and advocates of organic ingredients, we established our own manufacturing plants to produce our own brand of organic skin care. Today, we partner with contract manufacturers in the United Kingdom and the United States of America, where we oversee technical formulation, the use of natural ingredients, and quality assurance. This direct oversight has been a feature of our operations since 1994.

Our supply chains operate across the United Kingdom and the United States of America, with raw materials sourced globally for our organic product lines. This structure requires diligent oversight to identify and mitigate modern slavery risks.

Public Commitment

Biodeb Group Ltd publicly commits to achieving net zero carbon emissions by 2050 within the United Kingdom, in alignment with the government and NHS net zero ambition. We are actively engaged with sustainability and will report annually on our progress against Scope 1 and Scope 2 emissions, as well as key Scope 3 emissions categories relevant to our operations. This commitment forms part of our journey through the NHS Evergreen Sustainable Supplier Assessment framework.

2. Policies in Relation to Modern Slavery and Human Trafficking

Biodeb Group Ltd maintains a zero-tolerance approach to modern slavery, forced labour, human trafficking, and exploitation in all its forms. This commitment applies to our own operations, our employees and salon staff, our contract manufacturers worldwide, our raw material suppliers, our distributorship network, and any third parties acting on our behalf. The commitment extends equally to both trading entities, Radiant Glow Botanicals and Biodeb Consulting Ltd and to all subsidiaries.

The following policies support our modern slavery commitments:

• Supplier Code of Conduct – This policy requires all contract manufacturers and suppliers to comply with the Modern Slavery Act 2015 and relevant labour laws. It explicitly prohibits forced, bonded, or compulsory labour and requires all work to be voluntary, with workers free to terminate employment with reasonable notice. No worker shall be required to pay recruitment fees, deposits, or any other costs associated with obtaining employment. Original identification documents shall not be withheld from any worker. The Code also addresses child labour, working hours and wages, health and safety, non-discrimination, freedom of association, ethical business practices, and environmental responsibility. All suppliers must sign the Code and flow down its requirements to their own supply chains.
• Recruitment and Employment Policy – This ensures fair wages, voluntary employment, and no recruitment fees for workers. All employment decisions are based on merit and capability, and harassment or intimidation in any form is strictly prohibited.
• Whistleblowing Policy – This enables employees and contractors to report concerns confidentially and without fear of reprisal. Biodeb Group Ltd is committed to ensuring that all reports are taken seriously and investigated promptly.
• Employment Standards – This policy applies to all our employees, ensuring the ethical treatment of all hair and beauty professionals, including compliance with working time regulations and fair pay.
• Environmental Responsibility Policy – As an advocate of organic and natural ingredients, we maintain a policy of minimising waste, reducing energy and water consumption, and using sustainable materials wherever possible. We give preference to suppliers who demonstrate environmental responsibility.
• Ethical Sourcing Policy – We have developed and implemented a formal Ethical Sourcing Policy tailored to our global manufacturing partnerships. This policy requires all partners to maintain ethical labour practices and grants Biodeb Group Ltd the right to audit their facilities.

All policies are reviewed annually and updated as necessary to reflect changes in legislation, recognised best practice, or our supply chain structure. Our policies are communicated to all relevant staff and are made available to suppliers upon request.

3. Due Diligence Processes

Given our hands‑on technical oversight of contract manufacturers, we are well positioned to conduct meaningful due diligence. Our due diligence processes include:

• Supplier Selection and Vetting – We only partner with manufacturers who demonstrate compliance with international labour standards. Before entering any new manufacturing relationship, we conduct a risk assessment that includes reviewing the supplier's labour practices, compliance history, and any available third-party certifications.
• Contractual Requirements – Our manufacturing agreements include clauses requiring compliance with modern slavery legislation, the Biodeb Group Ltd Supplier Code of Conduct, and all relevant ethical labour standards. Non-compliance is grounds for immediate termination.
• Technical Oversight Visits – As part of our quality assurance role, we conduct regular visits to manufacturing sites in the United Kingdom and the United States of America. During these visits, our technical staff observe working conditions, including worker safety, facility conditions, and any visible indicators of labour exploitation. Our director, as a scientist, brings specialist expertise to these oversight activities.
• Right to Audit – Our Supplier Code of Conduct grants Biodeb Group Ltd the right to conduct announced or unannounced audits of supplier facilities, including document reviews, worker interviews, and site inspections. Audits may be conducted by our own staff or by an independent third party.
• Distributor Assurances – Our distributorship network is required to confirm their own ethical practices and comply with our Supplier Code of Conduct.
• Supply Chain Mapping – We have commenced a comprehensive mapping of our raw material supply chains for organic ingredients. This process, which will be completed during the 2026/27 financial year, will enable us to identify and address modern slavery risks at the primary production level.
• Modern Slavery Assessment Tool (MSAT) – We are committed to completing the government's Modern Slavery Assessment Tool to ensure a consistent and standardised approach to risk identification and management. This will align our due diligence processes with NHS requirements.

4. Risk Assessment and Management

We have conducted a risk assessment of our operations and supply chains to identify where modern slavery risks are most likely to arise. The following risks have been identified:

• Raw material sourcing (global) – This represents a medium risk area. We are currently mapping our raw material supply chains to identify the origin of all organic ingredients used in our products. Upon completion of this mapping, we will conduct targeted risk assessments and develop further mitigation measures.
• Contract manufacturing in the United States of America – This represents a low-risk area due to established legal frameworks and labour protections. Our ongoing oversight and contractual requirements provide additional assurance.
• Contract manufacturing in the United Kingdom – This represents our lowest risk area due to strong labour protections and our direct, hands‑on relationship with manufacturing partners.
• Distributorship network (Africa and other regions) – This represents a medium risk area. We require all distributors to comply with our Ethical Sourcing Policy and provide assurances regarding their own labour practices.
• Biodeb Consulting Ltd operations – As a consultancy providing expert advice on formulation and manufacturing, Biodeb Consulting Ltd does not operate its own manufacturing supply chains. However, we ensure that all recommendations made by the consultancy promote ethical sourcing and labour practices.

Our highest priority action for the 2026/27 financial year is to complete the mapping of our raw material supply chains and to extend our ethical standards beyond manufacturing and into primary production. This will enable us to identify and mitigate risks earlier in the supply chain.

We have established an internal governance structure for modern slavery and human rights, with the Director, as a scientist with technical oversight of all subsidiaries, holding ultimate responsibility for ensuring compliance across all business areas and supplier relationships. Each supply chain tier is assigned a responsible person who monitors compliance and reports any concerns.

5. Key Performance Indicators to Measure Effectiveness

We measure our effectiveness in ensuring that modern slavery is not taking place in our business or supply chains against the following key performance indicators, with targets for the 2026/27 financial year:

• Supplier Code of Conduct compliance – We will achieve 100% sign‑off of our Supplier Code of Conduct by all contract manufacturers in the United Kingdom and the United States of America. This will be measured through signed acknowledgement forms maintained in our supplier records.
• Technical oversight visits – We will conduct a minimum of two technical oversight visits to each manufacturing region (United Kingdom and United States of America) that specifically include observation of labour practices and working conditions. Each visit will be documented, and any concerns raised will be tracked to resolution.
• Staff training completion – We will achieve 100% completion of modern slavery awareness training for all relevant staff, including senior management, procurement personnel, supply chain staff, and salon management. Training records will be maintained and verified.
• Supply chain mapping – We will complete mapping of our raw material supply chains for organic ingredients by 31 March 2027. Completion will be verified by the Director.
• Modern Slavery Assessment Tool – We will complete the government's Modern Slavery Assessment Tool (MSAT) and achieve a score that meets or exceeds NHS requirements.
• Incident reporting – We will maintain zero confirmed instances of modern slavery in our supply chain. Any reported concerns will be investigated within 14 days, and findings will be documented.
• Evergreen Assessment – We will achieve and maintain a minimum Evergreen Sustainable Supplier Assessment Level 2 maturity score, which requires a published modern slavery statement and a structured approach to addressing modern slavery and driving social value.

These KPIs will be reviewed annually, and our performance will be reported in each year's Modern Slavery Statement.

6. Training on Modern Slavery and Human Trafficking

We recognise that effective training is essential to ensuring that all relevant personnel understand modern slavery risks and know how to respond to concerns. Our training programme is as follows:

• Training audience – The following roles and teams will receive modern slavery awareness training: senior management and directors, who are responsible for overall governance and strategic oversight; procurement and supply chain staff, who have direct contact with contract manufacturers and suppliers; quality assurance and technical oversight personnel, who conduct visits to manufacturing sites under the scientific leadership of our Director; administrative and human resources staff, who handle recruitment and employment matters; and staff of Biodeb Consulting Ltd, who advise clients on manufacturing and formulation practices.
• Training content – The training covers the following core topics: what modern slavery is, including forced labour, human trafficking, debt bondage, and child labour; the legal framework under the Modern Slavery Act 2015, including Section 54 reporting requirements and potential penalties for non-compliance; indicators of modern slavery in supply chains, such as workers appearing fearful or submissive, restricted freedom of movement, withholding of identification documents, poor living conditions, excessive overtime, and recruitment fees charged to workers; our company policies, including the Supplier Code of Conduct, the whistleblowing policy, and this Modern Slavery Statement; reporting procedures, including how to raise concerns confidentially, the protections available to whistleblowers, and the process for investigating reports; our due diligence processes, including how we assess suppliers and what staff should look for during technical oversight visits; and case studies relevant to the hair, wig, cosmetics, and personal care manufacturing industry.
• Training delivery – Training is delivered using a blended approach. Face‑to‑face sessions are held for senior management and key supply chain staff, allowing for interactive discussion and scenario‑based learning. Online modules are made available for all other staff, with a quiz at the end to confirm understanding. Printed guidance cards summarising key indicators and reporting contacts have been distributed to all staff who visit manufacturing sites or work in the salon.
• Training schedule and refreshers – All relevant staff will complete training by 31 December 2026. Refresher training will be delivered every two years. Any significant changes to our supply chain, such as new manufacturing partnerships, will trigger additional targeted training for relevant teams.
• Training records and evaluation – The Human Resources team maintains a training register recording the name and role of each participant, the date of training completion, and the method of delivery. Training effectiveness is measured through quiz scores for online modules, attendance records for face‑to‑face sessions, feedback forms collected after each session, and monitoring of reported concerns. An increase in appropriately reported concerns is treated as a positive indicator of greater awareness, not as a failure.

7. Corporate Social Value

Biodeb Group Ltd, through both subsidiary companies, is committed to delivering social value through our operations and supply chain. Our corporate social value programme aligns with the UN Sustainable Development Goals and the NHS Social Value Model. Key commitments include:

• Ethical employment – We provide fair wages, safe working conditions, and respect for worker rights across our own operations, including our salon and our UK manufacturing partners.
• Local economic development – Wherever possible, we prioritise working with local suppliers and manufacturers to support economic development in the communities where we operate.
• Environmental stewardship – As an advocate of organic and natural ingredients, we are committed to sustainable sourcing, waste reduction, and minimising our environmental footprint.
• Community engagement and knowledge sharing – Through Biodeb Consulting Ltd, our director, a scientist and speaker in organic skin care formulation, provides expert guidance to manufacturers, distributors, and the wider community. This supports education and awareness in Afro-Caribbean skin and hair care, promoting ethical and scientifically sound practices across the industry.

We will report annually on our social value outcomes as part of our Evergreen Assessment submission.