California Transparency in Supply Chains Act

Statement of Compliance as of October 1, 2025

1. Our commitment

Ruggable is committed to the prohibition of all forms of forced labor, including modern slavery and human trafficking, across all aspects of our operations and supply chains. We maintain a zero-tolerance approach towards modern slavery and will refrain from entering into business and/or will discontinue any current business with any third party organization which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labor. We will not knowingly trade or partner with any business or organization that supports or is found to be involved in these practices - directly or indirectly.

This statement is published in accordance with the California Transparency in Supply Chains Act and outlines the steps taken by Ruggable to prevent modern slavery and human trafficking in our operations and supply chains.

2. Definitions

Ruggable recognizes that modern slavery encompasses a range of exploitative practices, including but not limited to:

• Human trafficking;

• Forced labor, through mental or physical threat;

• Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;

• Dehumanization or commodification of individuals;

• Restrictions on freedom of movement.

3. Our supply chain

Ruggable uses a range of suppliers who provide goods, products for sale, services and support our operations. We understand that modern slavery risks can arise at any point in our supply chain, especially where sourcing occurs in high-risk geographies or industries. 

To mitigate these risks, we:

• Conduct supplier vetting and due diligence as part of our onboarding process;

• Require supplier contracts to include compliance with ethical labor standards; and

• Undertake audits and reviews of our facilities and partners.

Failure of suppliers to meet our expectations or refusal to cooperate with due diligence processes can result in corrective action up to and including the termination of all existing and future business.

4. Due Diligence and Risk Management

We are embedding modern slavery risk management across our procurement and supplier management processes. Our due diligence framework includes:

• Governance and policy checks; 

• Review of supplier labor practices; 

• Assessment of recruitment practices through compliance checking; and

• Integration of worker feedback mechanisms. 

We actively review any concerns raised by employees, partners, or third-party audits and take corrective action where appropriate.

5. Incident Response

Ruggable recognizes that modern slavery is widespread and may be uncovered even in well-managed supply chains. In the past year, we identified no suspected or confirmed cases of modern slavery across any tier of our supply chain. However, we remain committed to transparency and will take action regarding any instances of suspected or confirmed cases of modern slavery, including:

• Immediate escalation and investigation; 

• Remediation actions in collaboration with affected workers; 

• Reporting to relevant authorities; and

• Public disclosure in future authorities. 

6. Employee Training

Raising awareness and empowering colleagues is critical. As part of our ongoing commitment we will:

• Deliver mandatory e-learning to all employees; 

• Ensure that an up-to-date Modern Slavery policy is provided to all employees; and

• Make colleagues aware of all our business policies relating to standards of behavior that are required by them.  

7. Policies and Governance 

Ruggable has created several internal policies which aim to prevent modern slavery. These include:

• Agency Due Diligence Policy – Sets out the company’s standards for engagement of third-party agencies for staffing, manufacturing or related services; 

• Forced Labor Prohibition Policy – Prohibits the use of forced, bonded or child labor;

• Whistleblowing Policy – Encourages staff to report concerns or wrongdoing, including any related to modern slavery/trafficking and child or forced labor; and

• Supplier Code of Conduct – Zero tolerance stance to forced and child labor, restricted freedom of movement, unfair wages, extensive working hours and prohibiting confiscation of workers’ original identification documentation. 

8. Stakeholder Engagement

We recognize that effective action against modern slavery requires collaboration. We are continuing to work towards:

• Consulting with industry peers and NGOs; 

• Pilot engagement with workers, especially in high-risk supply chains; 

• Supporting multi-stakeholder initiatives where applicable; and 

• Sharing and adopting best practices. 

9. Looking Ahead

We will continue to enhance our procedures to help us identify, prevent and mitigate any risks of modern slavery or human trafficking in relation to new and existing suppliers. We are committed to ongoing improvement and will continue to evolve our approach.