Modern Slavery and Human Trafficking Statement

While Whirli is not currently required to publish a Modern Slavery Statement under Section 54 of the Modern Slavery Act 2015 (which applies to organizations with turnover exceeding £36 million), we voluntarily make this commitment as part of our journey toward B Corp certification and our dedication to ethical, transparent business practices.

This statement sets out the steps that Rotate-it Ltd (trading as Whirli) has taken and continues to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Whirli has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Whirli is a UK-based toy rental subscription service operating on circular economy principles. We serve families with children aged 0-8 years across the United Kingdom, extending the lifecycle of toys through sharing and reuse.

Our operations include:

• Toy procurement from established brand manufacturers and distributors
• Warehouse operations in Saltaire, Shipley, West Yorkshire
• Logistics and delivery services
• Technology platform development and maintenance
• Customer service operations

Our supply chain includes:

• Well-known toy brand manufacturers and authorized distributors
• Logistics and courier partners (including Royal Mail)
• Warehouse and facilities partners
• Technology service providers
• Cleaning and hygiene product suppliers

We recognise that the toy manufacturing industry, particularly overseas production, presents elevated risks for modern slavery and poor working conditions. Our approach focuses on partnering with established brands that maintain their own ethical manufacturing standards and published commitments to eliminating modern slavery from their operations.

Whirli is committed to ensuring transparency in our business and in our approach to tackling modern slavery throughout our supply chain.

Supplier Standards

We expect all suppliers to:

• Comply with all applicable laws regarding modern slavery and human trafficking
• Provide safe working conditions where necessary
• Treat workers with dignity and respect
• Act ethically and with integrity in all business dealings
• Maintain appropriate oversight of their own supply chains

Procurement Approach

Our procurement focuses on:

• Stocking exclusively well-known, established toy brands with proven track records in product safety and ethical manufacturing
• Partnering with brands that publish modern slavery statements or provide evidence of ethical manufacturing practices
• Monitoring brand partners' public commitments to worker welfare and supply chain transparency
• Leveraging the due diligence and audit capabilities of major manufacturers to ensure high standards

This approach allows us to benefit from the substantial resources larger toy manufacturers invest in supply chain oversight while ensuring the highest standards for the families we serve.

Current Practices

We mitigate modern slavery risks through:

• Selective brand partnerships with established toy manufacturers who maintain ethical manufacturing standards
• Monitoring of brand partners' published modern slavery statements and ethical commitments
• Awareness of toy industry standards and certifications (including ICTI Ethical Toy Program, Fair Trade, and similar schemes)
• Preference for suppliers with transparent supply chain practices

Ongoing Development

We are strengthening our due diligence processes as part of our B Corp certification journey, including:

• Formal supplier assessment and documentation procedures
• Enhanced verification of ethical manufacturing practices across our supply base
• Staff training on modern slavery awareness and risk indicators
• Implementation of clear reporting mechanisms for raising concerns

We maintain channels for employees, suppliers, and stakeholders to raise concerns about potential modern slavery issues:

• Contact: [email protected]
• All reports are treated confidentially and investigated thoroughly

We are committed to building awareness of modern slavery risks:

• Leadership team maintains awareness of modern slavery issues in the toy industry
• Key procurement and operations staff are trained on modern slavery risks and indicators
• Regular updates on modern slavery legislation and industry best practices
• Integration of ethical considerations into procurement decision-making

Whirli's core business model inherently reduces modern slavery risk by extending the lifecycle of existing toys through rental and reuse. Each toy in our library serves multiple families over several years, significantly reducing the need for new manufacturing.

Our Impact

• By keeping toys in circulation for longer, we reduce overall demand for new production
• Lower production demand means reduced pressure on manufacturing facilities globally
• Our model supports a more sustainable and ethical approach to toy consumption
• Every toy borrowed rather than bought new represents reduced manufacturing impact

We view this as an important complement to our supply chain due diligence - the most effective way to minimise modern slavery risk is to reduce unnecessary production in the first place.

We measure the effectiveness of our approach through:

• Brand partner assessment: Documentation and monitoring of ethical manufacturing commitments from our toy brand suppliers
• Supplier engagement: Regular review of supplier practices and published statements
• Staff awareness: Training completion rates for relevant personnel
• Incident reporting: Tracking and resolution of any modern slavery concerns raised
• Continuous improvement: Year-on-year enhancement of our verification processes

As we formalize and expand these processes, we will report on measurable progress in future annual statements.

Whirli is pursuing B Corp certification, which requires rigorous standards around worker welfare, supply chain ethics, and transparency. We are committed to:

• Implementing comprehensive supplier assessment and documentation processes
• Increasing our coverage of certified ethical manufacturers in procurement decisions
• Providing ongoing training to relevant staff on modern slavery risks and indicators
• Publishing annual updates demonstrating measurable progress
• Maintaining transparency about our supply chain practices and continuous improvement

We recognise that addressing modern slavery requires ongoing vigilance and commitment. We will continue to strengthen our due diligence processes year-on-year as we grow and as industry best practices evolve.

If you have any concerns or questions regarding this statement, or wish to report a concern about modern slavery in our supply chain, you can get in touch at [email protected] or by writing to Whirli Limited, Part Ground Floor Warehouse, Salts Mill, Victoria Road, Saltaire, Shipley, BD18 3LA, United Kingdom.

This statement covers the financial year ending 30 November 2025 and will be reviewed and updated annually.