1. Introduction

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This statement is made in accordance with applicable modern slavery and human trafficking legislation. We are committed to acting ethically and with integrity in all of our business dealings and relationships. We take a zero-tolerance approach to modern slavery in any form — including forced labor, debt bondage, human trafficking, child labor, and any other practice that deprives individuals of their freedom or exploits them for commercial gain. This statement sets out the steps we have taken and continue to take to ensure that slavery and human trafficking are not taking place anywhere in our business or supply chain.

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2. Our Business

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We are a product-based business operating in the e-commerce space, selling physical goods to consumers and authorized resellers. Our operations are based in the United States. We source, package, and distribute products and in doing so engage with a range of suppliers, manufacturers, and logistics partners. We recognize that supply chains — particularly those that extend internationally — carry an inherent risk of labor exploitation, and we take that risk seriously.

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3. Our Supply Chain

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Our supply chain includes the procurement of raw materials, product manufacturing, packaging, warehousing, and distribution. We are aware that the risk of modern slavery is not limited to manufacturing but can exist at any point in a supply chain, including in transportation, agriculture, and raw material extraction. We take a risk-based approach to identifying where exposure is highest and direct our oversight efforts accordingly. Where we work with international suppliers, we apply heightened scrutiny given the varying strength of labor protections across different jurisdictions.

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4. Our Policies

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We maintain internal policies that reflect our commitment to combating modern slavery and upholding the rights of workers throughout our supply chain. These include our Supplier Code of Conduct, which sets out the minimum standards we expect of every business we work with, our ethical sourcing guidelines, which govern how we select and retain suppliers, and our internal whistleblowing policy, which provides a safe and confidential channel for employees or third parties to raise concerns about labor practices without fear of retaliation. These policies are reviewed regularly and updated as our business and supply chain evolve.

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5. Due Diligence

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We conduct due diligence on our suppliers before entering into any commercial relationship and on an ongoing basis thereafter. This includes reviewing suppliers' own labor and human rights policies, requesting information about their working conditions and employment practices, assessing country-level and sector-level risk using publicly available resources and third-party assessments, and where appropriate, conducting or commissioning audits of supplier facilities. We do not work with suppliers who are unwilling to provide transparency into their operations or who fail to meet our minimum standards. Any supplier found to be engaged in practices consistent with modern slavery or forced labor will have their relationship with us terminated immediately.

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6. Risk Assessment

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We assess the risk of modern slavery across our supply chain by considering the countries in which our suppliers operate and the strength of labor law enforcement in those regions, the nature of the work involved and the vulnerability of the workforce, the complexity and length of our supply chain, and any red flags identified during supplier onboarding or ongoing monitoring. We recognize that risk is not static and commit to reassessing it regularly, particularly when we enter new supplier relationships, source from new regions, or expand our product range.

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7. Training & Awareness

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We are committed to ensuring that all relevant members of our team understand the risks of modern slavery and know how to identify and respond to warning signs. Staff involved in procurement, supplier management, and logistics are provided with guidance on recognizing indicators of forced labor and human trafficking, and on the steps to take if concerns are identified. We treat awareness of modern slavery as an ongoing responsibility, not a one-time exercise.

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8. Key Performance Indicators

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We measure the effectiveness of our efforts to combat modern slavery through the following indicators: the percentage of key suppliers who have signed and returned our Supplier Code of Conduct, the number of supplier audits or reviews conducted in the reporting period, the number of concerns or disclosures raised through our whistleblowing channel and the outcomes of those reports, and any instances of non-compliance identified and the actions taken in response. We commit to reporting on these indicators annually and to improving our performance over time.

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9. Reporting Concerns

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Any employee, supplier, contractor, or member of the public who has reason to believe that modern slavery or human trafficking is occurring within our business or supply chain is encouraged to report it immediately. Reports can be made confidentially to info@wolfgangklar.com All reports will be taken seriously, investigated promptly, and handled with discretion. We do not tolerate retaliation against anyone who raises a concern in good faith.

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10. Commitment & Sign-Off

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This statement has been approved by the senior leadership of our organization and reflects our genuine and ongoing commitment to eradicating modern slavery from our business and supply chain. It will be reviewed and updated annually to reflect the progress we have made and the steps we are taking going forward.

Signed: Max Alexander Wolfgang