Responsible Sourcing & Ethical Trading Policy

Atlantic Boba Ltd | Company No. NI738235

Effective: 5 April 2026 | Review: April 2027

1. Policy Statement

Atlantic Boba Ltd is committed to conducting its business with integrity, transparency and respect for human rights, labour standards and ethical principles throughout its supply chain. We source bubble tea ingredients primarily from manufacturers in China and Taiwan and take our obligations as an importer and food business operator seriously.

This policy applies to all operations, employees, contractors and suppliers of Atlantic Boba Ltd. Compliance with this policy is a condition of doing business with Atlantic Boba.

2. Modern Slavery and Human Trafficking

2.1 Atlantic Boba Ltd is committed to the prevention of modern slavery and human trafficking in all its forms. We will not knowingly trade with any organisation that engages in or tolerates any form of modern slavery.

2.2 Atlantic Boba publishes a Modern Slavery Transparency Statement in accordance with section 54 of the Modern Slavery Act 2015 (or will do so when required by that Act).

2.3 Anyone who suspects modern slavery or human trafficking in connection with our business should report this immediately to info@atlanticboba.co.uk or via our whistleblowing channel (clause 13).

3. Labour Standards and Working Conditions

Atlantic Boba expects all suppliers to uphold the following minimum labour standards, consistent with the ILO Core Conventions:

Workers are employed voluntarily and are free to leave employment with reasonable notice
No form of forced, bonded, trafficked or compulsory labour is used
All workers are paid at least the national or local minimum wage
Working hours comply with national laws and do not routinely exceed 48 hours per week
Workers are treated with dignity and respect; physical, verbal or psychological abuse is prohibited
Workers have the right to freedom of association and collective bargaining
All employment terms are clearly communicated in a language workers can understand

4. Child Labour

4.1 Atlantic Boba has a zero-tolerance approach to child labour. We will not knowingly source from suppliers that employ workers below the minimum legal working age in their country of operation, or below 15 years (whichever is higher), in accordance with ILO Convention No. 138.

4.2 We will not work with suppliers involved in the worst forms of child labour as defined in ILO Convention No. 182.

5. Non-Discrimination and Equal Opportunities

Atlantic Boba will not knowingly source from suppliers that engage in or permit discrimination against workers on the grounds of age, gender, pregnancy, race, ethnicity, nationality, religion or belief, disability, sexual orientation or trade union membership.

6. Health and Safety

6.1 All suppliers must maintain safe and healthy working environments in compliance with applicable national health and safety laws.

6.2 Suppliers operating food manufacturing facilities must hold appropriate food safety certifications relevant to their jurisdiction and product type (HACCP-based systems, ISO 22000, BRC or equivalent) and must make certification documentation available on request.

6.3 Atlantic Boba complies with all applicable health and safety legislation in Northern Ireland in relation to its own warehouse operations, including the Health and Safety at Work (Northern Ireland) Order 1978.

7. Anti-Bribery and Corruption

7.1 Atlantic Boba operates in strict accordance with the Bribery Act 2010 and will not offer, give, request or accept any bribe, kickback or improper payment in any form.

7.2 Atlantic Boba has adequate procedures in place, as contemplated by section 7 of the Bribery Act 2010, to prevent associated persons from bribing on its behalf.

7.3 Any supplier found to have engaged in bribery or corrupt practices will be removed from our supply base.

8. Food Fraud and Authenticity

8.1 Atlantic Boba will not knowingly participate in or facilitate the supply of adulterated, misrepresented or counterfeit food products.

8.2 Atlantic Boba maintains traceability records for all products received from suppliers and supplied to customers, enabling traceability one step back and one step forward in the supply chain.

8.3 All product specifications, ingredient declarations and certificates of analysis provided by suppliers are retained on file and made available to relevant regulatory authorities on request.

8.4 Atlantic Boba will conduct or commission pesticide maximum residue level (MRL) testing on applicable imported food products and will not dispatch any product that fails applicable MRL standards under retained EU Regulation (EC) No 396/2005.

9. Food Regulatory Compliance

9.1 Atlantic Boba is a registered food business operator with Lisburn and Castlereagh City Council (LCCC) and is subject to LCCC food safety inspections.

9.2 All food products imported by Atlantic Boba are subject to notification via IPAFFS (Import of Products, Animals, Food and Feed System) prior to arrival at the border control post and comply with applicable Common Health Entry Document (CHED-D) requirements.

9.3 Atlantic Boba operates in compliance with the Windsor Framework in relation to the movement of food products into and within Northern Ireland.

9.4 All products supplied are labelled in accordance with the UK Food Information Regulations 2014 and applicable retained EU food labelling legislation, including full ingredient declarations, allergen information and nutrition tables.

10. Supplier Assessment and Approval

Before placing initial orders, Atlantic Boba will conduct appropriate due diligence on new suppliers, which may include review of company registration documents; food safety certifications and audit reports; product specifications, ingredient declarations and certificates of analysis; assessment against the labour and ethical standards in this policy; and where appropriate, a supplier questionnaire.

Atlantic Boba reserves the right to decline to trade with, or to terminate trading with, any supplier that cannot demonstrate compliance with the standards in this policy.

11. Supplier Monitoring and Engagement

Atlantic Boba will review the performance and compliance of existing suppliers on at least an annual basis. Where concerns arise, Atlantic Boba will engage with the supplier to agree a remediation plan; suppliers that fail to remediate material breaches within a reasonable timescale will be removed.

Atlantic Boba recognises that most of its suppliers are based in China and Taiwan where audit capacity and transparency can be limited. We are committed to developing our supplier monitoring capability as the business grows.

12. Environmental Responsibility

Expectations regarding the environmental practices of suppliers are set out in Atlantic Boba's Environmental Policy. Suppliers are expected to comply with applicable environmental legislation in their country of operation and to make reasonable efforts to reduce their environmental impact.

13. Whistleblowing

Atlantic Boba encourages any employee, contractor, supplier or third party to raise concerns about conduct that may breach this policy, without fear of retaliation. Concerns can be raised by contacting info@atlanticboba.co.uk; all reports will be treated in confidence and investigated promptly.

Where concerns relate to potential criminal activity, individuals may also report to the Gangmasters and Labour Abuse Authority (GLAA), the Modern Slavery Helpline (08000 121 700) or the relevant regulatory authority.

14. Governance and Review

Overall responsibility for this policy rests with the directors of Atlantic Boba Ltd. The policy will be reviewed annually, or earlier if there is a material change in our operations, supply chain or applicable legislation.

Date of adoption: 5 April 2026 · Next review: April 2027 · Approved by: James Hickland, Director, Atlantic Boba Ltd.