ELF BAE LTD – Ethical Sourcing & Modern Slavery Statement

Last updated: August 2026

At ELF BAE LTD, we are committed to conducting our business responsibly, ethically and with respect for human rights.

As both a retailer and wholesale supplier operating through ElfBae.com, we recognise that responsible business practices extend beyond the products we sell. They also include the way products are manufactured, sourced, transported and supplied throughout the wider supply chain.

We do not tolerate:

modern slavery;
forced or compulsory labour;
human trafficking;
bonded labour;
unlawful child labour; or
other forms of exploitation.

Our objective is to work with suppliers, manufacturers, distributors and business partners that share similar standards of integrity, lawful employment and responsible sourcing.

1. About ELF BAE

ELF BAE LTD operates as a retailer and wholesale supplier of vaping, nicotine alternative and related products.

Through ElfBae.com, we supply individual retail customers as well as wholesale and trade customers.

Our supply chain may involve:

manufacturers;
brand owners;
importers;
distributors;
wholesalers;
logistics providers;
fulfilment providers;
technology providers; and
other commercial partners.

Because many products within our industry are manufactured or sourced internationally, we recognise the importance of maintaining awareness of potential labour and human-rights risks throughout the supply chain.

2. Our Approach

We believe businesses have a responsibility to operate with integrity and to take reasonable steps to avoid benefiting from exploitative labour practices.

Our approach is based on:

responsible sourcing;
appropriate supplier relationships;
transparency;
compliance with applicable laws;
awareness of supply-chain risk;
proportionate due diligence; and
taking appropriate action where concerns arise.

We aim to continually strengthen these practices as ELF BAE grows.

3. Scope of This Statement

This statement reflects the standards we expect across our business relationships.

It is relevant to:

ELF BAE employees;
directors;
contractors;
suppliers;
manufacturers;
distributors;
logistics partners;
professional service providers; and
other third parties working with or supplying ELF BAE.

We expect organisations we work with to comply with applicable employment, labour and human-rights laws within the jurisdictions in which they operate.

4. Modern Slavery

Modern slavery can take many forms.

This may include:

forced labour;
compulsory labour;
human trafficking;
debt bondage;
servitude;
slavery;
exploitation through threats or coercion; and
other situations where individuals are unable to leave employment freely.

ELF BAE does not knowingly support or engage with organisations involved in these practices.

Where credible concerns arise, we will consider the appropriate steps to investigate and address them.

5. Forced and Compulsory Labour

The use of forced, involuntary or compulsory labour is unacceptable.

Individuals working within our business or supply chain should:

work voluntarily;
be free from threats or coercion;
be free to leave employment in accordance with applicable law;
not be required to surrender identity documents unlawfully; and
not be subjected to unlawful recruitment fees, debt bondage or similar practices.

We expect suppliers to apply comparable standards within their own operations and supply chains.

6. Human Trafficking

ELF BAE has zero tolerance for human trafficking.

No person should be recruited, transported, transferred, harboured or exploited through force, deception, coercion or abuse of vulnerability.

If we become aware of credible evidence suggesting human trafficking within a supplier’s operation or supply chain, we will take the matter seriously and consider appropriate action.

7. Child Labour

ELF BAE does not support unlawful child labour.

Suppliers and business partners should comply with all applicable:

minimum working-age requirements;
compulsory education requirements;
restrictions relating to hazardous work; and
employment protections for young workers.

We expect suppliers to take reasonable steps to ensure that unlawful child labour is not used within their own operations or supply chains.

8. Fair Working Conditions

We believe individuals should be treated fairly, respectfully and with dignity.

We expect suppliers and business partners to comply with applicable laws and standards relating to:

wages;
working hours;
rest periods;
health and safety;
employment rights;
discrimination;
harassment; and
working conditions.

Where local legislation provides stronger protections, those legal standards should be followed.

9. Safe Working Environments

Workers should be provided with safe and appropriate working environments.

We expect businesses within our supply chain to take reasonable steps to:

identify workplace hazards;
reduce avoidable risks;
provide appropriate safety equipment;
maintain suitable emergency procedures;
provide appropriate training; and
comply with applicable health and safety requirements.

Responsible manufacturing should not come at the expense of worker safety.

10. Respect and Equal Treatment

ELF BAE supports fair and respectful treatment in the workplace.

We do not support discrimination or exploitation based on protected or personal characteristics.

We expect suppliers to provide workplaces where employees are treated fairly and are not subjected to:

physical abuse;
threats;
harassment;
intimidation;
degrading treatment; or
unlawful discrimination.

11. Freedom of Employment

Employment should be freely chosen.

Workers should not be forced to remain in employment through:

threats;
withholding wages;
retention of passports or identity documents;
unlawful deposits;
debt bondage;
intimidation; or
other coercive practices.

Workers should be able to leave employment subject to lawful and reasonable notice arrangements.

12. Responsible Recruitment

We encourage responsible and transparent recruitment practices.

Where recruitment agencies or labour providers are used, we expect suppliers to take reasonable steps to ensure workers are recruited lawfully and fairly.

This includes avoiding practices that could place workers into exploitative debt or make them dependent upon an employer or recruiter.

13. Supply Chain Responsibility

Our products may pass through several stages before reaching ELF BAE and our customers.

These stages may include:

raw-material sourcing;
component production;
manufacturing;
assembly;
packaging;
international transportation;
importing;
warehousing; and
distribution.

We recognise that visibility can become more difficult further down a complex supply chain.

We therefore seek to work with reputable organisations and encourage our direct suppliers to maintain appropriate standards within their own supplier relationships.

14. Supplier Expectations

We expect suppliers and business partners to:

comply with applicable modern-slavery and human-rights legislation;
prohibit forced labour and human trafficking;
prohibit unlawful child labour;
maintain appropriate employment practices;
provide safe working conditions;
treat workers fairly;
maintain reasonable visibility over their own supply chains; and
respond appropriately where concerns are identified.

We also encourage suppliers to expect comparable standards from organisations supplying them.

15. Supplier Selection

When choosing suppliers, ELF BAE considers a range of commercial and operational factors.

Depending on the relationship and level of risk, these may include:

reputation;
product quality;
regulatory compliance;
supply reliability;
business transparency;
sourcing practices;
manufacturing arrangements; and
willingness to respond to compliance enquiries.

Ethical considerations may form part of our wider assessment when deciding whether to establish or continue a supplier relationship.

16. Risk-Based Due Diligence

Our approach to modern-slavery risk is intended to be proportionate to the nature of our business and supply chain.

Where appropriate, we may undertake steps such as:

requesting supplier information;
reviewing company and sourcing information;
requesting declarations or supporting documentation;
discussing manufacturing arrangements;
reviewing publicly available compliance information;
investigating reported concerns; and
conducting additional checks where a higher level of risk is identified.

The nature and extent of due diligence may vary depending on the supplier, product, country of manufacture and information available to us.

17. Higher-Risk Supply Chains

Certain sectors, geographical locations or manufacturing processes can present higher labour and exploitation risks.

Factors that may influence our assessment include:

complex international supply chains;
manufacturing in jurisdictions with weaker labour protections;
extensive reliance on temporary or migrant labour;
limited supply-chain transparency;
unusually low manufacturing costs;
credible reports of labour abuses; and
reluctance to provide reasonable sourcing information.

Where such risks are identified, we may consider additional due diligence appropriate.

18. Working With Manufacturers and Importers

ELF BAE may purchase products directly or indirectly from manufacturers, importers, distributors and brand owners.

We aim to work with established organisations capable of providing appropriate information regarding their products and supply arrangements.

Where reasonably required, we may seek further information about:

manufacturing locations;
product origin;
supplier relationships;
compliance procedures;
quality-control processes; and
ethical sourcing policies.

19. Wholesale Supply Chain

As a wholesale supplier, ELF BAE recognises that our responsibilities extend beyond purchasing products for our own retail operation.

Our trade customers rely on us as part of their own supply chain.

We therefore aim to build our wholesale operation around:

responsible sourcing;
reliable suppliers;
transparent commercial relationships;
regulatory awareness;
product quality; and
appropriate supply-chain oversight.

Our goal is to give trade customers greater confidence in the businesses supplying the products they ultimately sell to consumers.

20. Retail Responsibility

Our retail operation also gives ELF BAE direct visibility into the products entering the consumer market.

We believe responsible sourcing should form part of the overall customer experience alongside:

product quality;
compliance;
competitive pricing;
availability; and
customer service.

The products customers purchase through ElfBae.com should come through supply relationships that we are comfortable supporting.

21. Raising Concerns

We encourage employees, suppliers, business partners and other individuals to raise credible concerns relating to:

modern slavery;
human trafficking;
forced labour;
child labour;
unsafe working conditions;
unethical recruitment; or
other serious exploitation.

Concerns should be raised through the contact information available on ElfBae.com.

Where sufficient information is available, we will consider the matter and determine the appropriate response.

22. Investigating Concerns

Where a credible concern is raised, we may take steps including:

requesting information from the relevant supplier;
seeking supporting documentation;
discussing the allegation with the parties involved;
reviewing the supplier relationship;
seeking professional advice where appropriate; and
taking further action according to the seriousness of the issue.

We will aim to approach concerns fairly and proportionately.

23. Action Where Problems Are Identified

Our response to an identified issue will depend on its nature and severity.

Possible actions may include:

requesting corrective action;
requiring additional information;
increasing supplier monitoring;
temporarily suspending purchases;
removing products from our supply chain;
terminating a supplier relationship; or
reporting matters to appropriate authorities where legally required or otherwise appropriate.

Our priority is to avoid knowingly supporting exploitative practices.

24. Working With Suppliers to Improve Standards

Where an issue can appropriately be remedied, immediate termination of a commercial relationship may not always produce the best outcome for affected workers.

Depending on the circumstances, we may consider whether working with the relevant supplier to achieve meaningful corrective action is more appropriate.

However, serious violations, deliberate concealment or unwillingness to address identified problems may result in suspension or termination of the relationship.

25. Training and Awareness

As ELF BAE grows, we aim to improve awareness of modern-slavery and responsible-sourcing risks among relevant members of our team.

Where appropriate, guidance may cover:

recognising warning signs;
understanding supplier risk;
responsible purchasing;
escalating concerns;
identifying unusual employment practices; and
understanding the importance of supply-chain transparency.

Training and awareness measures will be proportionate to employees’ responsibilities.

26. Purchasing Decisions

Our purchasing decisions are based on multiple considerations including:

product demand;
pricing;
quality;
regulatory compliance;
supplier reliability;
product availability; and
commercial viability.

Where relevant information raises serious ethical or human-rights concerns, those concerns may also influence whether we purchase from a particular supplier.

Commercial advantage does not justify knowingly supporting exploitative labour practices.

27. Continuous Improvement

We recognise that responsible supply-chain management is an ongoing process.

No business operating within an international product supply chain can assume that risks will never arise.

Our approach is therefore to continually improve our understanding, supplier relationships and internal processes as ELF BAE develops.

This may include:

improving supplier records;
strengthening due-diligence procedures;
reviewing higher-risk relationships;
improving contractual expectations;
increasing staff awareness; and
monitoring changes in legislation and industry practice.

28. Record Keeping

Where appropriate, we may maintain records relating to:

supplier assessments;
compliance enquiries;
reported concerns;
investigations;
corrective actions; and
decisions concerning supplier relationships.

Appropriate record keeping helps us maintain consistency and demonstrate the steps taken where concerns arise.

29. Modern Slavery Act 2015

The Modern Slavery Act 2015 forms an important part of the UK’s legal framework addressing modern slavery and human trafficking.

ELF BAE supports the principles behind this legislation and is committed to conducting business in a way that seeks to prevent modern slavery and exploitation.

Where statutory modern-slavery reporting or other obligations apply to ELF BAE, we will seek to comply with those requirements.

Irrespective of whether a particular statutory reporting requirement applies to us at a given time, we believe responsible sourcing and opposition to modern slavery should remain part of our business practices.

30. International Standards

We support the underlying principles of internationally recognised labour and human-rights standards.

Where appropriate, we encourage suppliers to operate consistently with principles reflected in recognised international frameworks concerning:

forced labour;
child labour;
freedom of association;
discrimination;
fair employment; and
safe working environments.

Applicable national laws must always be observed.

31. Responsibility Within Our Supply Chain

Responsibility for ethical sourcing is shared throughout the supply chain.

Manufacturers, importers, distributors, wholesalers and retailers all have a role to play in encouraging lawful and responsible business practices.

As ELF BAE operates in both retail and wholesale, we recognise our position between suppliers and the businesses and consumers purchasing products from us.

We aim to use that position responsibly.

32. Expectations of Our Business Partners

We expect organisations working with ELF BAE to:

conduct business lawfully;
treat employees fairly;
avoid exploitative labour practices;
maintain appropriate workplace standards;
respond transparently to reasonable compliance enquiries; and
take action if modern slavery is identified within their own supply chain.

Where appropriate, we encourage our direct suppliers to communicate similar expectations to their suppliers.

33. No Retaliation for Genuine Concerns

Individuals should feel able to raise genuine concerns about unethical or unlawful conduct.

ELF BAE does not support retaliation against any person who raises a genuine modern-slavery or human-rights concern in good faith.

Deliberately false or malicious allegations are different from genuine concerns and may be handled accordingly.

34. Review of This Statement

We will review this Modern Slavery Statement periodically.

Reviews may take account of:

growth of our business;
changes to our supplier base;
entry into new markets;
changes to applicable legislation;
identified supply-chain risks;
relevant industry developments; and
experience gained through our sourcing activities.

Where appropriate, this statement will be updated to reflect changes in our approach.

35. Contact ELF BAE

If you have a genuine concern relating to modern slavery, human trafficking, forced labour, child labour or unethical practices connected with ELF BAE or our supply chain, please contact us through ElfBae.com.

Please provide as much relevant information as reasonably possible so that we can assess the concern.

ELF BAE LTD
44 Century Square
Peterborough
England
PE1 3FR

Company Number: 14468196
Website: ElfBae.com

Our Ethical Sourcing Commitment

ELF BAE is committed to growing our business responsibly.

Whether we are selecting products for our retail customers or sourcing stock for our wholesale partners, we believe strong commercial relationships should be built on more than price alone.

They should also be built on:

Integrity. Transparency. Fair treatment. Responsible sourcing.

As our business and supply chain continue to grow, we will continue working to strengthen the standards we expect from ourselves and the organisations we choose to work with.

Modern Slavery Statement