Modern Slavery Statement

Introduction

Our Modern Slavery statement is published by Thread 35 Limited t/a Sosandar (“Sosandar”) in accordance with the requirements set out in the Modern Slavery Act 2015 which covers the financial year ending 31 March 2026 where turnover reached £42.3m.

This statement explains the steps Sosandar has taken during the financial year ending 31 March 2026 to identify, prevent and mitigate the risk of modern slavery and human trafficking within its own operations and supply chain. It also sets out the actions planned for 2026/27 to strengthen governance, supplier due diligence, training and supply chain transparency.

We remain completely opposed to slavery in all its forms. This statement outlines the steps Sosandar is taking to prevent modern slavery across our business and supply chain, and sets out our commitments for 2026/27 in further detail below.

As an expanding business with a growing national and international presence, we recognise that modern slavery risks can exist within complex fashion supply chains, particularly where supply chains are fragmented or lack transparency. This statement outlines the steps we have taken to help ensure that modern slavery is not present within our operations or supply chain.

About Sosandar and our Supply Chain

Sosandar was founded in 2016 by two multi award winning female entrepreneurs, Ali Hall, and Julie Lavington, who between them have over 40 plus years’ experience in Fashion and Media.

Since opening our first standalone store in September 2024, we have expanded our retail presence to five stores across the UK. The brand now operates as a full-price multichannel retailer, supported by our key stakeholders and supply chain partners, all of whom are expected to uphold the fundamental principles relating to the prevention of modern slavery.

We understand that our business has an impact on the world around us and we are dedicated to ensuring that impact remains positive. Throughout the design and manufacturing of all our merchandise, Sosandar has a deep commitment to responsible practices, and we are dedicated to working with suppliers who share our belief in operating responsibly and with a high level of integrity.  

Our sourcing strategy is fully focused on building key, long-term partnerships around the globe with our products now manufactured through 54 suppliers across 87 T1 facilities in 12 countries, including China, India, Vietnam, Turkey and several EU countries. This approach supports our strategy to consolidate the number of factories within our current supply base, improving traceability and reduces operational risks.

We are continuing to strengthen our audit verification and supplier management processes through the implementation of a platform solution with one of our key supply chain compliance providers. This system is modernising the way we capture, manage, and verify supply chain data, supporting improved traceability and transparency beyond Tier 1 factories. To date, we have fully mapped and independently audited our Tier 1 factories through the platform, with 60% of our suppliers also providing visibility of their Tier 2 and Tier 3 facilities.

Improving transparency remains central to our sustainability journey. Greater supply chain visibility helps us identify environmental hotspots, strengthen labour standards, make informed sourcing decisions, reduce risk, and report accurately against current and future legislation.

To guarantee our high standards are maintained, we regularly conduct comprehensive assessments of ethical, sustainable and manufacturing practices throughout our supply chain. Our Sourcing, Compliance and Technical teams oversee this process to safeguard the consistent upholding of our ‘Code of Conduct’ and relevant business policies at every level of our operation. 

Sourcing Sustainable Fabrics and Packaging

Our journey to sourcing product more sustainably is ongoing as we look to continuously enhance our operations. 100% of our leather is sourced from Leather Working Group accredited Gold and Silver graded tanneries. This supports our commitment to responsible leather sourcing by ensuring that the tanneries we work with are assessed against recognised standards covering environmental impact, water and energy use, chemical management and waste reduction.

We have increased the use of recycled fibres in our ranges. An example is within our swimwear ranges. In 2024, recycled nylon accounted for 25% of the range, increasing to 50% across 2025 and 2026. As we develop our SS27 collection, we are working to further expand the number of recycled nylon options within the category.

We are also continuing to introduce more responsibly sourced materials throughout our collections, including ECOVERO™ viscose and recycled polyester.

This reflects our commitment to making more responsible material choices and sustainability considerations as we build our ranges.

As part of our ongoing environmental strategy, we remain committed to minimising waste by using recyclable and sustainable packaging wherever possible. We are proud to report that 100% of our inbound garment polybags are made from fully recycled materials, and our outbound consumer bags are crafted from 50% bio-based material and 30% recycled content.

In addition, 100% of our woven garment labelling is produced using recycled fibres, for example, our care labels which are produced using recycled polyester, equate to approximately 500 square metres of recycled material used over the past 12 months. However, we recognise that there is always more to do and our commitment to reducing the impact we have on the environment is a priority over the coming years. 

Due Diligence

At Sosandar, we implement a comprehensive due diligence approach to evaluate, monitor, and mitigate potential business risks and prevent human rights violations. Recognising that human rights protection is crucial and continuously evolving, we have established policies, processes, and standards to closely oversee our supply chain and ensure compliance with relevant regulations and industry best practices. 

Code of Conduct

We use this code to outline the minimum requirements that all product suppliers must uphold in relation to their workers such as employment being freely chosen, no harsh or inhumane treatment of workers, and ensuring that child labour is not used. This code is aligned to the Ethical Trading Initiative (ETI) Base Code, which is founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice. The code is contained in our supplier onboarding portfolio.  

We require all suppliers to sign a declaration confirming that each of their manufacturing facilities and/or third-party subcontractors producing goods does so in accordance with the ETI base code and local law, which must be returned to us before production commences.

Supplier Terms and Conditions and Policies

All suppliers are contractually bound by the terms and conditions set out in our onboarding process which includes key ethical policies. These cover areas such as anti-slavery, human trafficking, anti-bribery, and whistleblowing.  

Further fundamental policies relating to modern slavery are communicated to our suppliers and throughout our business covering areas such as:

Cotton fibre sourcing,

Environmental chemical policy,

Animal welfare standards,

Prohibited or restricted sources,

Sourcing in high-risk areas and,

REACH compliance.

Risk Assessment, Prevention and Mitigation

Risk assessment is crucial to our strategies and decision-making regarding suppliers, sourcing, and overall business operations. We consider various factors when evaluating risks, such as the country and region of origin, supplier setup and ethical practices, and applicable local and international legislation. 

We reserve the right in our terms of business to audit/visit all factories either directly or through an industry recognised third party. Such audits include, but are not limited to, a review of universal rights in accordance with the UN Guiding Principles; responsible recruitment; entitlement to work, immigration; sub-contracting and homeworking.  

Our suppliers are only permitted to use production facilities and/or third-party subcontractors that we have approved in advance.  

Our approach is to give clear guidance on expectations with our supply base promoting full transparency at both onboarding stage and through ongoing supplier communications.  

To increase our visibility and understand our supply chain, we have fully mapped our Tier 1 production sites and champion in person factory visits by our Sourcing, Compliance and Product teams. Regular visits to all main production territories give us the opportunity to discuss sustainable and ethical working conditions face to face, as well as give us first hand visibility and knowledge of better practices.  

When and if problems are discovered, we work with suppliers to ensure the best outcome for all concerned parties.      

Third Party Audits

We request annual audits from Tier 1 manufacturing sites within Sosandar’s supply chain to ensure our standards are met. We also require other key documents, including:

A Full Audit report from independent and internationally recognised companies such as SMETA (Sedex Members Ethical Trade Audit) or BSCI (Business Social Compliance Initiative) ensuring our global supply chain complies with expected standards.

Completed and signed supplier forms including the Sosandar Terms of Business.

Completed factory set-up forms.

The audits assess areas including working conditions, working hours and wages. Sosandar’s Sourcing and Compliance team reviews each audit thoroughly. If non-compliance is identified during an audit, we work with suppliers to ensure issues are resolved and closed with the relevant audit body within 30–60 days. While we recognise the benefits of this process, we are committed to working alongside our supply base to embed a system of continuous improvement that goes beyond audits.

Sosandar defines its tiers as follows:

Sosandar Employees & Training

Our employees have access to, and sign to comply with, a staff handbook, which details various policies supporting our commitment to responsible business. It protects the rights of both our direct and indirect employees and promotes an ethical supply chain. These include, but are not limited to our Code of Conduct, Grievance Procedure, Whistleblowing policy and our Anti-Bribery policy.

We ensure that the required legal checks are completed for all employees who join Sosandar, and we only work with recruitment agencies who mirror our commitment to onboarding people responsibly.

Next Steps – 2026/27

During the financial year 2026/27, we plan to take the following key steps to further strengthen our approach to identifying and mitigating the risks of modern slavery and human trafficking across our supply chains:

Strengthen supplier onboarding and due diligence: Update our supplier onboarding documentation, including the Supplier Handbook and related policies, to embed modern slavery due diligence throughout the supplier relationship. This will support continuous risk identification, monitoring and management, ensuring risks are assessed and addressed throughout the partnership lifecycle, rather than solely at onboarding.
Maintain regulatory compliance: Continue to explore opportunities to work with external partners and specialist agencies to support Sosandar in maintaining compliance with current and emerging regulations and legislation across the UK and internationally.
Enhance supplier management and performance monitoring: Continue to strengthen supplier partnerships and communication to ensure ongoing alignment across all parties. Enhance our in-house supplier management processes through regular performance assessments and annual risk assessments, supported by clear metrics to measure and monitor ESG performance, compliance and audit outcomes.
Strengthen internal awareness and training: Ensure key personnel across the wider business receive up-to-date training on responsible and sustainable sourcing, including modern slavery risks, country-specific challenges and relevant business policies and procedures.
Diversify sourcing and strengthen strategic partnerships: Strengthen strategic supplier partnerships in key territories while exploring new sourcing regions to reduce geographic concentration and mitigate geopolitical and supply chain risk. We plan to increase our nearshore sourcing mix to reduce reliance on offshore routes affected by geopolitical pressures and supply chain disruption. This will also help to manage capacity more effectively and avoid placing undue pressure on existing suppliers, factories and workers.
Increase supply chain transparency: Continue to improve supply chain transparency. To date, we have fully mapped and independently audited our Tier 1 factories, with 60% of our suppliers also providing visibility of their Tier 2 and Tier 3 facilities. Over the next 12 months, we aim to achieve that 100% of our suppliers provide us with visibility of Tier 2 facilities, supporting greater risk identification and management, and contributing to our readiness for upcoming compliance requirements.
Reduce packaging and assess alternatives: Continue to explore packaging alternatives and keep our approach aligned with developments in sustainable materials and regulatory requirements. This will include a target to reduce non-essential packaging and implement procedures to reuse applicable packaging elements and assess packing methods across the supply chain. We aim to have 50% of our cardboard and paper packaging certified by the FSC.
Increase the use of verifiable sustainable materials: Aiming 25% of our products to be sourced using verifiable sustainable materials, supported by appropriate documentation and supplier evidence to substantiate these claims.

This statement was approved by the Board of Directors in August 2026 and is made regarding section 54(1) of the Modern Slavery Act 2015 and constitutes our ongoing commitment to ending slavery and human trafficking for good.

Signed for, and on behalf of, the Board:

Julie Lavington and Ali Hall

Co-CEOs

Date: August 2026