MSA

IDON SRLS

MODERN SLAVERY, FORCED LABOUR & HUMAN TRAFFICKING STATEMENT

Financial Year: 2026

1. Introduction and Statement of Commitment

IDON SRLS is committed to conducting its business according to the highest standards of ethics, integrity, respect for human rights and social responsibility.

We recognise that modern slavery, forced labour, child labour, human trafficking, servitude, debt bondage and other forms of labour exploitation are serious violations of fundamental human rights and may occur at different levels of global supply chains.

IDON SRLS has zero tolerance for modern slavery, forced labour, human trafficking, child labour or any other form of coercive, abusive or exploitative employment practice within our own operations or those of our suppliers, manufacturers, subcontractors and business partners.

Although IDON SRLS may not currently meet the statutory thresholds requiring publication of a Modern Slavery Statement under certain national laws, we have voluntarily adopted this Statement as part of our commitment to responsible business conduct and supply-chain transparency.

This Statement is designed to reflect internationally recognised principles and, where relevant to our activities, the standards and disclosure areas established by major international modern-slavery and forced-labour frameworks, including:

  • the Australian Modern Slavery Act 2018 (Cth);

  • the United Kingdom Modern Slavery Act 2015, including Section 54;

  • applicable United States laws and regulations addressing forced labour and human trafficking in supply chains and imports, including Section 307 of the U.S. Tariff Act of 1930;

  • the Uyghur Forced Labor Prevention Act (UFLPA);

  • the California Transparency in Supply Chains Act;

  • applicable European Union and Italian human-rights, labour and responsible-business requirements;

  • the United Nations Guiding Principles on Business and Human Rights (UNGPs);

  • the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct and relevant OECD due-diligence principles;

  • the International Labour Organization (ILO) Fundamental Principles and Rights at Work and relevant ILO Conventions concerning forced labour, child labour, freedom of association and discrimination.

Our objective is not merely to satisfy formal compliance requirements where applicable, but to establish a responsible sourcing framework capable of identifying, preventing, mitigating and, where necessary, remediating human-rights risks throughout our operations and supply chain.

2. Reporting Entity

The reporting entity covered by this Statement is:

IDON SRLS, an Italian limited liability company engaged in the design, development, production, marketing, licensing, distribution and sale of consumer products, principally wooden puzzles and related products.

IDON SRLS is incorporated in Italy.

As a non-Australian entity, IDON SRLS does not have an Australian Business Number (ABN) unless separately registered for one in Australia.

This Statement covers IDON SRLS's own operations and the supply chains used to produce and distribute its products.

Where IDON SRLS works with independent manufacturers, suppliers, logistics providers, contractors, agents, distributors or other business partners, we seek to apply the principles contained in this Statement to those relationships to the extent relevant and proportionate.

3. Our Business and Operations

IDON SRLS develops and commercialises wooden puzzles and related consumer products for customers and commercial partners in multiple international markets.

Our activities may include:

  • product concept development;

  • graphic and product design;

  • intellectual-property licensing;

  • sourcing of materials and components;

  • manufacturing;

  • product assembly;

  • printing;

  • packaging;

  • quality control;

  • warehousing;

  • logistics and transportation;

  • wholesale distribution;

  • e-commerce;

  • marketing and advertising;

  • relationships with licensors, retailers, marketplaces and other commercial partners.

Our business model involves collaboration with specialised third-party manufacturers and suppliers.

We recognise that our responsibility to respect human rights extends beyond our direct employees and therefore consider risks arising throughout the relevant supply chain, including risks associated with raw materials, components, manufacturing, packaging, logistics and subcontracted activities.

4. Our Supply Chain

Our supply chain may include direct and indirect suppliers involved in:

  • timber and wood-based materials;

  • paper and cardboard;

  • printing materials;

  • inks, paints, coatings and adhesives;

  • wooden packaging and product boxes;

  • product packaging;

  • manufacturing and assembly;

  • cutting and finishing processes;

  • printing and graphic reproduction;

  • labels and accessories;

  • warehousing;

  • freight forwarding;

  • courier and transportation services;

  • technology and professional services supporting our operations.

We recognise that modern-slavery risks may occur beyond Tier 1 suppliers and can arise at earlier stages of production, including the extraction, harvesting, processing or manufacture of raw materials.

For this reason, we encourage our direct suppliers to apply equivalent human-rights and labour standards to their own suppliers and subcontractors.

5. Our Human Rights Principles

IDON SRLS believes that every worker involved in our operations and supply chain must be treated with dignity and respect.

Our approach is based on the fundamental principle that all employment must be freely chosen.

No worker should be compelled to work through force, threats, intimidation, violence, deception, abuse of vulnerability, financial pressure, retention of identity documents or any other form of coercion.

Our suppliers and business partners are expected to respect internationally recognised human rights and all applicable labour laws in the jurisdictions in which they operate.

Where local legal requirements provide lower protection than internationally recognised standards, we encourage suppliers to apply the higher standard wherever legally permissible.

6. Prohibition of Forced Labour and Modern Slavery

IDON SRLS prohibits, and expects its suppliers to prohibit:

  • forced or compulsory labour;

  • slave labour;

  • bonded labour;

  • debt bondage;

  • indentured labour;

  • involuntary prison labour;

  • trafficking in persons;

  • servitude;

  • coercive recruitment;

  • forced overtime;

  • work obtained through threats or intimidation;

  • restriction of workers' freedom of movement;

  • withholding of wages as a means of coercion;

  • recruitment practices that create debt bondage;

  • retention of passports or identity documents as a condition of employment;

  • deposits or financial guarantees imposed on workers as a condition of employment;

  • threats of denunciation to immigration or other authorities;

  • any practice preventing a worker from freely terminating employment in accordance with applicable law.

Workers must be able to enter and leave employment voluntarily, subject only to reasonable and lawful notice requirements.

7. Responsible Recruitment and Recruitment Fees

We recognise that recruitment practices can represent a significant source of forced-labour and human-trafficking risk, particularly for migrant, temporary and agency workers.

IDON SRLS expects suppliers to ensure that:

  • workers are not charged recruitment fees or other inappropriate fees in order to obtain employment;

  • recruitment agencies are legitimate and operate in accordance with applicable law;

  • employment terms are explained to workers before employment begins;

  • employment contracts are provided in a language the worker can reasonably understand;

  • contracts accurately describe wages, working hours, benefits and working conditions;

  • contract substitution is prohibited;

  • workers are not deceived about the nature or location of their work;

  • migrant workers are not subjected to discriminatory or coercive recruitment practices;

  • workers retain control of their passports, identity documents and personal belongings.

Where a worker is found to have paid prohibited recruitment fees connected to employment in our supply chain, IDON SRLS expects the relevant supplier to investigate and take appropriate corrective and remedial action.

8. Child Labour and Young Workers

IDON SRLS has zero tolerance for unlawful child labour.

Suppliers must comply with all applicable minimum-age legislation and must not employ children below the minimum legal working age.

IDON SRLS expects suppliers to respect internationally recognised standards concerning child labour, including the principles reflected in relevant ILO Conventions.

Young workers who are legally permitted to work must not perform work that:

  • is hazardous;

  • interferes with compulsory education;

  • is inappropriate for their age;

  • exposes them to dangerous machinery, chemicals or working environments;

  • requires unlawful night work or excessive working hours.

Where child labour is identified, the priority should be the welfare and best interests of the child. Corrective action should seek responsible remediation rather than simply removing the child from the workplace in a manner that could cause additional harm.

9. Wages, Benefits and Working Hours

IDON SRLS expects suppliers to comply with applicable laws and regulations concerning:

  • minimum wages;

  • overtime compensation;

  • legally mandated benefits;

  • social-security obligations;

  • working hours;

  • rest periods;

  • holidays;

  • annual leave;

  • maternity and other statutory leave.

Workers should receive clear and understandable information regarding their wages and working conditions.

Wages must be paid regularly and directly to workers.

Unlawful or disciplinary wage deductions are not acceptable.

Overtime must be managed in accordance with applicable law and must not be imposed through threats, penalties or other coercive measures.

10. Freedom of Movement and Personal Documents

Workers must retain reasonable freedom of movement.

Suppliers must not use unreasonable restrictions on workers entering or leaving workplaces or accommodation provided by an employer.

Workers must normally retain possession and control of their:

  • passports;

  • national identification documents;

  • residence permits;

  • work permits;

  • bank cards;

  • personal property.

Temporary access to original documentation for legitimate administrative purposes should occur only where lawful, necessary and with the worker's informed consent, and documents should be returned promptly.

11. Freedom of Association and Worker Representation

IDON SRLS respects the right of workers, in accordance with applicable law, to:

  • organise;

  • form or join trade unions;

  • participate in lawful collective bargaining;

  • elect worker representatives;

  • communicate collectively with management;

  • refrain from joining such organisations if they choose.

Workers must not face intimidation, harassment, retaliation or discrimination for exercising lawful rights of association or worker representation.

Where local law restricts formal freedom of association, suppliers are encouraged to permit lawful alternative mechanisms for independent worker communication and representation.

12. Non-Discrimination, Harassment and Humane Treatment

All workers must be treated with dignity and respect.

IDON SRLS does not tolerate:

  • physical abuse;

  • sexual harassment;

  • sexual abuse;

  • verbal abuse;

  • psychological abuse;

  • intimidation;

  • threats;

  • degrading treatment;

  • corporal punishment;

  • discriminatory employment practices.

Employment decisions should be based on legitimate professional considerations and comply with applicable anti-discrimination laws.

13. Health and Safety

Safe and healthy working conditions are an essential component of responsible employment.

Suppliers are expected to:

  • comply with applicable occupational health and safety laws;

  • identify workplace hazards;

  • maintain appropriate fire and emergency procedures;

  • provide suitable personal protective equipment where necessary;

  • provide appropriate safety training;

  • maintain machinery and equipment in safe operating condition;

  • provide access to clean drinking water and sanitary facilities;

  • appropriately manage hazardous substances;

  • investigate workplace accidents and take corrective action;

  • provide safe accommodation where worker accommodation is supplied.

Serious health and safety deficiencies may also be considered indicators of broader labour exploitation and will therefore be taken seriously as part of our responsible-sourcing approach.

14. Supplier Standards and Expectations

IDON SRLS expects suppliers, manufacturers, contractors and relevant business partners to conduct their operations consistently with the principles contained in this Statement.

Suppliers are expected to:

  1. comply with applicable labour and human-rights laws;

  2. prohibit forced labour, slavery and human trafficking;

  3. prohibit unlawful child labour;

  4. ensure employment is freely chosen;

  5. provide lawful wages and benefits;

  6. comply with applicable working-time requirements;

  7. maintain safe and healthy working conditions;

  8. prevent harassment, abuse and discrimination;

  9. respect lawful worker rights;

  10. maintain accurate employment and payroll records;

  11. cooperate with reasonable compliance enquiries;

  12. promptly investigate credible allegations of labour exploitation;

  13. implement corrective actions where deficiencies are identified;

  14. communicate equivalent expectations to relevant subcontractors and suppliers.

Compliance with these principles is considered an important factor in our supplier-selection and supplier-management processes.

15. Subcontracting

Unauthorised or undisclosed subcontracting can reduce supply-chain visibility and increase human-rights risks.

IDON SRLS therefore expects suppliers to exercise appropriate oversight of subcontractors used in connection with our products.

Where relevant, suppliers may be asked to:

  • disclose significant subcontracted manufacturing activities;

  • identify the location at which production takes place;

  • confirm that subcontractors comply with applicable labour laws;

  • communicate IDON SRLS's responsible-sourcing expectations to subcontractors;

  • cooperate with reasonable requests for information concerning subcontracted production.

IDON SRLS reserves the right to raise concerns regarding subcontractors where reasonable human-rights or labour-compliance concerns exist.

16. Supply-Chain Risk Assessment

IDON SRLS adopts a risk-based approach to modern-slavery due diligence.

We recognise that risk may vary according to:

  • country of manufacture;

  • raw-material origin;

  • industry sector;

  • production process;

  • use of migrant labour;

  • use of temporary or agency workers;

  • use of labour recruiters;

  • prevalence of subcontracting;

  • supplier transparency;

  • regulatory environment;

  • known human-rights concerns;

  • credible governmental or international risk information.

Our internal operations are considered comparatively low-risk because of the nature and scale of our direct workforce and activities.

Nevertheless, we recognise that manufacturing and raw-material supply chains can present higher risks, particularly at upstream levels where visibility may be more limited.

Accordingly, we do not assume that the absence of identified incidents means that no risk exists.

17. Geographic Risk

Geographic location alone does not determine whether a supplier is acceptable.

However, country-specific conditions can be relevant to our assessment of modern-slavery risk.

Where appropriate, IDON SRLS may consider:

  • prevalence of forced labour;

  • prevalence of child labour;

  • migrant-worker vulnerability;

  • strength and enforcement of labour laws;

  • credible governmental warnings;

  • sanctions and trade restrictions;

  • forced-labour import restrictions;

  • credible reports from international organisations;

  • sector-specific human-rights risks.

Higher-risk locations or circumstances may result in enhanced due diligence.

18. Raw Materials and Product Traceability

We recognise that modern-slavery risk can arise in raw-material supply chains even where the final manufacturing facility itself operates responsibly.

For wooden products, relevant upstream considerations may include the sourcing and processing of timber, wood-based materials, paper and packaging.

IDON SRLS therefore seeks, where reasonably practicable and proportionate to risk, to maintain visibility regarding significant materials and their suppliers and may request supporting information from manufacturing partners.

We encourage suppliers to maintain records enabling reasonable traceability of relevant raw materials and components.

19. United States Forced-Labour Import Compliance

IDON SRLS recognises that goods imported into the United States may be subject to specific restrictions concerning forced labour.

Accordingly, we seek to avoid sourcing products, components or raw materials that we know or reasonably suspect to have been produced wholly or partly through forced labour.

Our risk-assessment approach may consider relevant U.S. government information concerning forced labour, including applicable import restrictions, enforcement actions and high-risk entities or regions.

Where relevant, suppliers may be requested to provide information concerning:

  • manufacturing locations;

  • raw-material origin;

  • component suppliers;

  • upstream suppliers;

  • production records;

  • purchase documentation;

  • other information reasonably necessary to establish supply-chain traceability.

Particular care is taken where applicable U.S. legislation establishes heightened forced-labour risks or import restrictions, including those associated with the Uyghur Forced Labor Prevention Act.

IDON SRLS does not knowingly source products or materials produced using forced labour.

20. Supplier Due Diligence

Supplier due diligence may include, depending on risk and circumstances:

  • reviewing supplier background and reputation;

  • assessing location and industry risk;

  • requesting company and manufacturing information;

  • requesting compliance declarations;

  • requesting confirmation of adherence to labour laws;

  • discussing labour and ethical-sourcing requirements;

  • reviewing available certifications or audit information;

  • requesting additional documentation where concerns arise;

  • monitoring supplier performance;

  • escalating concerns for additional review.

Due diligence is proportionate to the nature, scale and level of risk associated with the supplier relationship.

21. Supplier Verification

IDON SRLS may verify supplier compliance through a combination of:

  • supplier declarations;

  • direct communication;

  • documentation;

  • production information;

  • compliance certificates;

  • third-party information;

  • risk-screening resources;

  • factory information;

  • audits or inspections where considered appropriate.

Verification measures may be conducted internally or, where appropriate, through qualified third parties.

The level and form of verification will depend on the circumstances and assessed risk.

22. Supplier Certification

IDON SRLS expects its direct suppliers to comply with all applicable laws concerning slavery, forced labour, child labour and human trafficking in the countries in which they operate.

Where considered appropriate, IDON SRLS may require suppliers to provide written certification or contractual confirmation that:

  • their operations comply with applicable labour laws;

  • forced labour and human trafficking are prohibited;

  • unlawful child labour is prohibited;

  • relevant materials and products have not knowingly been produced using prohibited forced labour;

  • equivalent expectations are communicated to relevant subcontractors.

Providing false or misleading compliance information is considered a serious matter.

23. Audits and Inspections

IDON SRLS reserves the right, where contractually permitted and appropriate to the circumstances, to request or undertake additional verification of supplier compliance.

This may include:

  • announced audits;

  • independent third-party audits;

  • review of existing social-compliance audits;

  • factory inspections;

  • document reviews;

  • worker-related compliance enquiries;

  • corrective-action follow-up.

The absence of routine independent or unannounced audits for every supplier should not be interpreted as an absence of supplier oversight. IDON SRLS applies a proportionate, risk-based approach and may increase the level of scrutiny where risks or concerns are identified.

24. Warning Signs and Indicators

Employees involved in sourcing, procurement or supplier management are encouraged to remain alert to potential indicators of exploitation, including:

  • workers appearing unable to leave employment freely;

  • retention of passports or identity documents;

  • excessive recruitment fees;

  • unexplained wage deductions;

  • workers owing significant debts to recruiters or employers;

  • restriction of movement;

  • threats or intimidation;

  • excessive or involuntary overtime;

  • unsafe or overcrowded accommodation;

  • evidence of underage workers;

  • inconsistent employment records;

  • deceptive recruitment;

  • withholding of wages;

  • workers being unable to communicate freely;

  • unexplained subcontracting;

  • suppliers refusing reasonable transparency regarding production locations.

The presence of one indicator does not necessarily establish modern slavery, but it may justify further investigation.

25. Purchasing Practices

IDON SRLS recognises that irresponsible purchasing practices can contribute indirectly to poor labour conditions.

We therefore seek to maintain constructive and commercially reasonable relationships with our manufacturing partners.

Where reasonably practicable, we seek to avoid purchasing behaviour that could create unnecessary pressure leading suppliers to compromise lawful labour standards, including unrealistic production deadlines or unjustified last-minute changes.

Our preference for stable, long-term supplier relationships helps support transparency, communication and continuous improvement.

26. Training and Awareness

Relevant personnel involved in:

  • procurement;

  • supplier management;

  • production;

  • operations;

  • logistics;

  • management;

are encouraged to understand the principal risks associated with modern slavery and forced labour.

Training and internal guidance may cover:

  • definitions of modern slavery;

  • forced-labour indicators;

  • child-labour risks;

  • recruitment-fee risks;

  • passport-retention risks;

  • supply-chain transparency;

  • escalation procedures;

  • supplier due diligence;

  • responsible purchasing practices.

Training requirements will be reviewed periodically and strengthened where appropriate.

27. Reporting and Grievance Mechanisms

IDON SRLS encourages employees, workers, suppliers, contractors, commercial partners and other stakeholders to raise concerns regarding suspected unethical or unlawful conduct.

Concerns may include:

  • suspected forced labour;

  • human trafficking;

  • child labour;

  • worker coercion;

  • unsafe working conditions;

  • unlawful recruitment practices;

  • retention of identity documents;

  • wage abuse;

  • harassment or intimidation;

  • other serious violations of this Statement.

Reports should be treated seriously and, where appropriate, confidentially.

IDON SRLS prohibits retaliation against persons who raise genuine concerns in good faith.

28. Investigation of Concerns

Where credible concerns relating to modern slavery or serious labour exploitation are identified, IDON SRLS will seek to respond proportionately and responsibly.

Depending on the circumstances, actions may include:

  1. gathering additional information;

  2. requesting an explanation from the supplier;

  3. requesting supporting documentation;

  4. escalating the issue internally;

  5. requesting corrective action;

  6. establishing a remediation timetable;

  7. increasing supplier monitoring;

  8. commissioning or requesting an audit where appropriate;

  9. temporarily suspending new orders where necessary;

  10. terminating the relationship in serious or unresolved circumstances.

Our priority is to prevent harm and improve outcomes for affected workers.

29. Remediation and Victim-Centred Approach

IDON SRLS recognises that immediately terminating a supplier relationship may, in some circumstances, worsen conditions for affected workers.

Where an issue is identified, we therefore seek to consider the nature and severity of the harm and the interests of affected workers before determining the appropriate response.

Where appropriate and practicable, remediation may include requiring a supplier to:

  • cease the offending practice;

  • return identity documents;

  • repay unlawful recruitment fees;

  • repay improperly withheld wages;

  • correct employment contracts;

  • improve working conditions;

  • remove coercive restrictions;

  • strengthen recruitment controls;

  • provide additional training;

  • implement enhanced monitoring;

  • protect workers from retaliation.

Severe violations, deliberate concealment, failure to cooperate, repeated non-compliance or failure to implement corrective action may result in suspension or termination of the business relationship.

30. Non-Retaliation

No employee, supplier worker or other individual should suffer retaliation for raising a legitimate concern regarding modern slavery, forced labour, human trafficking or another serious labour-rights issue in good faith.

Retaliation itself will be considered a serious compliance concern.

31. Internal Accountability

Responsibility for ethical business conduct ultimately rests with the management of IDON SRLS.

Relevant employees and contractors are expected to comply with IDON SRLS policies and applicable law.

Intentional participation in, concealment of or disregard for serious human-rights violations may result in appropriate corrective or disciplinary measures and, where necessary, termination of the relevant relationship.

Management is responsible for promoting awareness of this Statement and ensuring that material concerns are appropriately escalated.

32. Supplier Accountability

Suppliers are expected to cooperate transparently with reasonable enquiries concerning labour and human-rights compliance.

Where deficiencies are identified, IDON SRLS may require a corrective-action plan containing:

  • the identified issue;

  • required corrective action;

  • responsible party;

  • expected completion date;

  • supporting evidence;

  • follow-up verification.

The seriousness of the issue and supplier responsiveness will be considered when determining whether the relationship can continue.

33. Measuring Effectiveness

IDON SRLS recognises that policies alone are insufficient and that the effectiveness of our approach should be periodically assessed.

Relevant indicators may include:

  • percentage of key suppliers subject to compliance review;

  • number of supplier compliance declarations obtained;

  • number of suppliers subject to enhanced due diligence;

  • number and nature of modern-slavery concerns identified;

  • number of corrective-action plans issued;

  • completion rate of corrective actions;

  • number of supplier relationships suspended or terminated for serious compliance concerns;

  • relevant employee training and awareness activities;

  • improvements in supply-chain traceability;

  • responsiveness of suppliers to compliance requests.

The relevance and usefulness of these indicators will be reviewed over time.

34. Record Keeping and Documentation

Where appropriate, IDON SRLS seeks to maintain reasonable documentation supporting its modern-slavery and responsible-sourcing activities.

This may include:

  • supplier information;

  • supplier declarations;

  • compliance correspondence;

  • audit or inspection information;

  • corrective-action documentation;

  • supply-chain information;

  • training records;

  • internal assessments;

  • relevant certifications.

Appropriate documentation helps us assess risks, demonstrate progress and respond to customer, licensor or regulatory enquiries.

35. Collaboration with Customers, Licensors and Business Partners

IDON SRLS recognises that preventing modern slavery requires cooperation across the value chain.

We therefore seek to cooperate in good faith with reasonable human-rights, ESG, responsible-sourcing and modern-slavery due-diligence requests from:

  • customers;

  • retailers;

  • licensors;

  • marketplaces;

  • commercial partners;

  • distributors;

  • regulatory authorities.

Where partners maintain their own supplier codes or modern-slavery requirements, we seek to understand and comply with applicable contractual obligations.

36. Continuous Improvement

Modern-slavery risk management is an ongoing process.

IDON SRLS is committed to progressively strengthening its systems as the business and supply chain develop.

Our objectives include:

  • improving supplier mapping;

  • strengthening supplier due diligence;

  • increasing upstream supply-chain visibility;

  • improving raw-material traceability where appropriate;

  • formalising supplier compliance declarations;

  • strengthening contractual human-rights provisions;

  • enhancing internal training;

  • improving risk-assessment procedures;

  • developing measurable compliance indicators;

  • improving documentation and record keeping;

  • reviewing relevant regulatory developments;

  • improving grievance and remediation procedures.

37. Future Supplier Requirements

As our responsible-sourcing programme develops, IDON SRLS intends to continue strengthening the integration of modern-slavery considerations into supplier onboarding and ongoing supplier management.

Depending on risk and proportionality, enhanced requirements may include:

  • formal Supplier Codes of Conduct;

  • annual compliance declarations;

  • modern-slavery questionnaires;

  • factory identification requirements;

  • subcontractor disclosure;

  • raw-material origin information;

  • audit rights;

  • corrective-action requirements;

  • termination rights for serious human-rights violations.

38. Compliance with Applicable Laws

All suppliers and business partners are expected to comply with applicable laws and regulations in the jurisdictions in which they operate.

Nothing in this Statement is intended to replace or reduce any stricter legal or contractual requirement.

Where a specific law, customer requirement, licensor requirement or contractual obligation imposes a higher standard, IDON SRLS will seek to apply that higher standard where applicable.

39. Regulatory Alignment

This Statement has been structured to address, on a voluntary basis and where relevant, key disclosure themes found in major international modern-slavery frameworks.

Australia

The Statement addresses:

  • identification of the reporting entity;

  • structure, operations and supply chains;

  • modern-slavery risks;

  • actions taken to assess and address risks;

  • due diligence and remediation;

  • assessment of effectiveness;

  • governance and other relevant information.

Where consultation with owned or controlled entities is legally required, this criterion will be addressed according to the corporate structure applicable during the relevant reporting period.

United Kingdom

The Statement addresses the principal transparency areas concerning:

  • organisational structure and supply chains;

  • policies;

  • modern-slavery risk assessment;

  • due diligence and remediation;

  • training and awareness;

  • monitoring and assessment of effectiveness.

United States

The Statement addresses:

  • forced-labour risk;

  • human trafficking;

  • supply-chain verification;

  • supplier accountability;

  • product and material traceability;

  • forced-labour import restrictions;

  • enhanced risk associated with relevant regions and entities.

California

The Statement addresses the principal disclosure categories of:

  • verification;

  • supplier audits;

  • supplier certification;

  • internal accountability;

  • training.

40. No Known Tolerance for Modern Slavery

IDON SRLS's position is unequivocal:

Modern slavery, forced labour, human trafficking and unlawful child labour have no place in our business or supply chain.

We expect every organisation involved in producing, handling or supplying our products to share this principle.

We will not knowingly benefit from or continue supporting practices involving slavery, trafficking or forced labour.

Where credible concerns are identified, we will seek to investigate and respond appropriately.

41. Review of This Statement

This Statement will be reviewed periodically and is intended to be updated annually where appropriate.

The review may take into consideration:

  • changes to our business;

  • changes to our supply chain;

  • supplier performance;

  • identified risks;

  • regulatory developments;

  • international guidance;

  • customer and licensor requirements;

  • lessons learned from due-diligence activities.

IDON SRLS is committed to continuous improvement rather than treating modern-slavery compliance as a one-time exercise.

42. Management Approval

This Modern Slavery, Forced Labour & Human Trafficking Statement for Financial Year 2026 has been reviewed and approved by the management of IDON SRLS.

It represents IDON SRLS's commitment to respecting human rights, maintaining responsible business practices and working to prevent modern slavery, forced labour, child labour and human trafficking throughout our operations and supply chain.

Approved on behalf of IDON SRLS

Name: Nicolò Ragazzini

Position: Director / Authorised Representative

Date: 01/01/2026

APPENDIX A – CORE SUPPLIER REQUIREMENTS

Suppliers working with IDON SRLS are expected to:

  1. prohibit all forms of forced and compulsory labour;

  2. prohibit slavery, servitude and human trafficking;

  3. prohibit debt bondage and bonded labour;

  4. prohibit unlawful child labour;

  5. prohibit involuntary prison labour;

  6. ensure employment is freely chosen;

  7. prohibit recruitment-related coercion;

  8. prevent workers from being charged inappropriate recruitment fees;

  9. prohibit unlawful retention of passports and identity documents;

  10. respect workers' freedom of movement;

  11. provide lawful wages and benefits;

  12. comply with applicable working-hour requirements;

  13. provide safe and healthy working conditions;

  14. prohibit harassment, abuse and discrimination;

  15. respect lawful freedom of association and worker representation;

  16. maintain accurate employment and payroll records;

  17. maintain appropriate oversight of labour recruiters;

  18. maintain appropriate oversight of subcontractors;

  19. communicate responsible-labour expectations through their own supply chains;

  20. cooperate with reasonable IDON SRLS due-diligence enquiries;

  21. promptly disclose serious labour-rights concerns relevant to IDON SRLS products;

  22. implement corrective actions where deficiencies are identified;

  23. prohibit retaliation against workers raising legitimate concerns;

  24. provide truthful and accurate compliance information;

  25. comply with all applicable human-rights, labour, anti-trafficking and forced-labour laws.

APPENDIX B – MODERN SLAVERY RISK INDICATORS

IDON SRLS considers the following examples potential indicators requiring further attention:

  • restriction of movement;

  • passport confiscation;

  • recruitment debt;

  • withheld wages;

  • excessive recruitment fees;

  • threats or violence;

  • threats of deportation;

  • deceptive recruitment;

  • contract substitution;

  • involuntary overtime;

  • excessive working hours combined with coercion;

  • worker isolation;

  • inability to terminate employment;

  • unexplained deductions;

  • unlawful child labour;

  • unsafe worker accommodation;

  • dependency on an employer for immigration status combined with coercive practices;

  • hidden subcontracting;

  • suppliers refusing to disclose manufacturing locations;

  • inconsistent or falsified employment documentation;

  • evidence of state-imposed forced labour;

  • credible governmental or international forced-labour warnings.

The existence of an indicator does not automatically establish a violation. It may, however, trigger further investigation or enhanced due diligence.

APPENDIX C – RESPONSE AND REMEDIATION FRAMEWORK

Where a potential modern-slavery issue is identified, IDON SRLS's response may follow the following process:

Identify → Assess → Investigate → Protect → Remediate → Monitor → Review

Identify

Receive or identify the concern.

Assess

Evaluate credibility, severity, scale and potential impact.

Investigate

Obtain relevant information while seeking to avoid increasing risk to affected workers.

Protect

Consider immediate measures necessary to protect workers from further harm or retaliation.

Remediate

Require appropriate corrective and remedial measures.

Monitor

Verify implementation of agreed corrective actions.

Review

Assess lessons learned and determine whether broader changes to sourcing or compliance controls are required.

Where remediation is impossible, serious violations persist or a supplier refuses to cooperate, IDON SRLS reserves the right to suspend or terminate the commercial relationship.

APPENDIX D – EFFECTIVENESS AND CONTINUOUS IMPROVEMENT FRAMEWORK

IDON SRLS seeks to assess its progress through four core areas:

1. Prevention

  • supplier expectations;

  • responsible sourcing;

  • risk screening;

  • contractual safeguards.

2. Detection

  • supplier communication;

  • documentation;

  • risk indicators;

  • due diligence;

  • audits or inspections where appropriate.

3. Response

  • escalation;

  • investigation;

  • corrective action;

  • remediation;

  • supplier accountability.

4. Improvement

  • annual review;

  • training;

  • improved traceability;

  • supplier engagement;

  • updated policies and procedures.

This framework is intended to evolve as IDON SRLS's operations, supply chains and regulatory obligations develop.

FINAL COMMITMENT

IDON SRLS believes that commercial success must never come at the expense of fundamental human rights.

We are committed to working responsibly with our employees, suppliers, manufacturers, customers, licensors and other partners to promote ethical working conditions and responsible global supply chains.

Our goal is to ensure, to the greatest extent reasonably possible through effective risk-based due diligence, that the products we develop and sell are produced under conditions that respect the dignity, freedom, safety and fundamental rights of the people involved in their production.

IDON SRLS – Financial Year 2026