Modern Slavery Statement
Last updated: 22 September 2026
Statement of Commitment
This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and sets out the steps Big Potato has taken during the financial year ending February 2026 to prevent slavery and human trafficking from taking place in its business or supply chains.
Big Potato does not tolerate modern slavery, forced or bonded labour, human trafficking, or child labour in any part of its own operations or its supply chain, and is committed to acting ethically and with integrity in all business relationships.
1. Organisation Structure, Business and Supply Chains
Big Potato Games is a certified B Corporation, based at 2nd Floor, 63 Gee St, London, EC1V 3RS.
This statement is made on behalf of Big Potato Holdings Limited, covering Big Potato Enterprises Limited and its three trading subsidiaries - Big Potato Limited, Big Potato Games EU GmbH and Big Potato USA Inc.
As of our August 2026 ESG supplier review, Big Potato's tier-1 supply chain comprises 12 assessed suppliers: 8 factory manufacturers producing games, game components and packaging - based in China (Zhejiang, Guangdong and Jiangsu provinces) and Hong Kong (with production across the border in Dongguan and Shenzhen) - and 4 logistics, warehousing and freight-forwarding providers based in the UK, Germany, the USA and Canada. Some tier-1 suppliers in turn use their own named subcontractors (for example, packaging suppliers used by our logistics providers), giving us partial visibility into a second supply chain tier; full sub-tier mapping is not yet complete for every supplier.
We continue to extend our ESG assessment coverage across our supply chain, including to further top suppliers by spend, and expect coverage to grow further during the next reporting period. Supplier assessments received during the year are reviewed and incorporated into our scoring on an ongoing basis.
2. Our Policies
Our approach is set out in the following internal policies, which are reviewed and communicated to employees, suppliers and partners:
- Human Rights Policy - sets out our commitments on forced labour, human trafficking and child labour, treatment of workers, wages and working hours, freedom of association, health and safety, and diversity and inclusion.
- Supplier Code of Ethics - sets out mandatory labour rights, working conditions, and responsible sourcing requirements for suppliers, including a prohibition on retention of identity documents, restrictions on accommodation-linked control of workers, and a named-region sourcing restriction covering the Xinjiang Uyghur Autonomous Region.
- Grievance / Report a Concern channel - a confidential route (reportaconcern@bigpotato.co.uk) for suppliers and third parties to raise human rights concerns without fear of retaliation.
- Grievance / Whistleblowing policy on Hi-Bob - a confidential route for employees to raise human rights concerns without fear of retaliation.
3. Due Diligence
We assess human rights risk across our operations and supply chain, considering country of operation, industry sector and nature of work, with higher-risk areas subject to enhanced due diligence. New suppliers are screened against ethical standards before onboarding, and ongoing relationships are monitored for continued compliance.
Where relevant, we require evidence of responsible sourcing certification for key raw material categories - for example FSC or PEFC certification for wood or paper-based materials, as set out in Section 4 below. Many of our factory suppliers subcontract specialist production processes as a routine part of manufacturing; we are working with suppliers to improve our visibility of these arrangements.We reserve the right to request information, and to conduct announced and unannounced audits, either directly or through third-party auditors.
In August 2026, all 12 assessed tier-1 suppliers were scored against a weighted ESG scorecard (Human Rights 45%, Environmental Practices 30%, Ethics & Governance 25%), each broken down into policy, labour-practice and supply-chain-oversight sub-scores, with automatic risk flags raised for issues including missing modern slavery policies, absent supplier oversight, unclear Xinjiang Region sourcing, recruitment fees, and refusal to confirm key policies. Where non-conformances are identified, we work with suppliers on corrective action plans, and may suspend orders or terminate the business relationship where adequate remediation is not achieved.
4. Risk Assessment and Management
We treat certain sourcing categories as inherently higher-risk and apply specific controls:
- Region-specific restriction: no sourcing of raw materials, production or services linked to the Xinjiang Uyghur Autonomous Region, given the documented risk of forced labour in that region.
- Wood-based products: sourced from responsibly managed forests, certified preferentially to FSC and at minimum to PEFC.
- Chemical inputs: controlled sourcing of inks, coatings, adhesives and plastics against applicable safety standards.
Combining 2025 spend with our supplier risk data, we review our most material procurement relationships each year, considering spend, volume, and the severity and likelihood of potential human rights impacts. This year’s review has identified our largest supplier by spend and our largest freight and logistics supplier by spend as priority relationships, with assessment continuing across our wider supply chain as part of our ongoing ESG review process.
5. Effectiveness - Key Performance Indicators
Big Potato tracks the following supplier human rights due diligence metrics, drawn from our live ESG Supplier Risk Tracker:
• Supplier assessment coverage: 100% of tier-1 suppliers (12 of 12) were assessed for human rights and wider ESG risk in the August 2026 review cycle.
• Risk profile: all assessed suppliers are risk-rated against our weighted ESG scorecard, and suppliers rated High risk are subject to enhanced monitoring and a defined corrective action plan.
• Corrective action follow-through: high-priority corrective actions identified through supplier assessment are tracked to a defined deadline and reviewed at the supplier’s next scheduled reassessment.
This is the first year these metrics have been tracked in this form, so no prior-year comparison is yet available.
6. Training
Our Human Rights Policy commits to providing relevant training to employees involved in procurement, supply chain management and compliance, to ensure they can identify and address human rights risks. Relevant training is delivered via Atlas Training's Modern Slavery Awareness course, and is required for our Operations, Supply Chain, Production and Sourcing teams, together with our Senior Management team, given their role in approving and signing this Statement. Senior Management completes the same course as operational teams. Training is completed at onboarding and refreshed annually thereafter, with completion tracked internally and by Atlas Training. A training-completion KPI will be reported in future years’ Statements once a full year cycle of tracking data is available.
Approval
This statement was approved by the Board of Big Potato on 22.09.26 and is signed on its behalf by:
Signed:Adam Wright
Role: Co- CEO
Date: 22.09.26