Modern Slavery and Human Trafficking Statement 2025

Master Distributor Ltd (MDL) T/A Cloud Nine is a family business. We distribute hair styling and beauty products direct to customers and through key B2B Accounts within the UK, Europe, Australia, New Zealand and the UAE.

The company headquarters are located in Harrogate, North Yorkshire and has distribution sites in the UK, The Netherlands, Australia and New Zealand. We source our products from multiple countries in Europe, USA, China and South Korea.

"We are committed to eradicating all instances of modern slavery and human trafficking across our entire business operations and supply chain, in accordance with Section 54 of the UK Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018. We undertake ongoing risk assessments and implement measures to prevent, detect, and address modern slavery risks."

This statement reflects our commitment to acting ethically and with integrity in all our business relationships, and to implement and enforce effective systems and controls to ensure no slavery or human trafficking exists anywhere in our supply chains. Ultimate responsibility for the prevention of modern slavery rests with the Company’s leadership. The Group Management Board has overall responsibility for ensuring this policy and its implementation comply with our legal, moral, and ethical obligations. Leaders at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery.

We have implemented policies to ensure that in all areas of the business and within our supply chain, we act ethically and with integrity and transparency.

The following internal policies are in place the ensure we are conducting our business in an ethical manner;

1. Recruitment policy: All employees are paid above the national minimum living wage. We ensure ‘eligibility to work in the UK’ checks for all employees are completed to safeguard against human trafficking.

2. Equal opportunities: This policy offers all employees equal treatment, taking into
consideration all protected characteristics. This is set out to avoid any potential
discrimination at work.

3. Whistleblowing: We operate a whistleblowing policy so that all employees can freely raise concerns about how colleagues are being treated or concerns with practices within the business or supply chain, without fear or reprisals.

4. GDPR: All individuals associated with CLOUD NINE have the right to their personal
information being protected under the General Data Protection Regulations, implemented May 2018.

5. Modern Slavery Policy: Ensuring all employees, contractors, supplier and business partners of MDL are aware of our commitment and their responsibility to ensure that slavery and human trafficking do not occur within our operations or supply chains.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. We ensure that all of our people understand how to safely raise any concerns they may have about possible instances of modern slavery or human trafficking within our own operations or our supply chains. Colleagues have been reminded of the Group Whistle-blowing Policy as the primary method of reporting any suspicious or evidence of slavery or human trafficking.

MDL condemns modern slavery and human trafficking. We are dedicated to the prevention of modern slavery throughout our operations and supply chains. To identify and mitigate risk we regularly audit key suppliers to ensure their adherence to our policies and compliance to legal standards as well as best practise for all employment related concerns, such as working hours, fair pay and working conditions. All employees are subject to identification checks which include obtaining proof that they are eligible to work in the UK.

• Continue annual audits with our main suppliers to ensure adherence to our policies and compliance to legal standards as well as best practise for all employment related concerns.
• Complete updated risk analysis of our direct suppliers with a view to focus on those deemed higher risk.
  

MDL remains dedicated to continuing efforts to assess and address modern slavery risks in its operations and supply chain.