Modern Slavery and Human Trafficking Policy

Kingston Trading (UK) Ltd t/a Kingston E-Liquids
Last updated: November 2025

1. Policy Statement

Kingston Trading (UK) Ltd is committed to conducting all business activities ethically, responsibly, and in compliance with the Modern Slavery Act 2015.

We have a zero-tolerance approach to modern slavery, human trafficking, forced labour, and child labour in any part of our operations or supply chain.

We recognise our responsibility to act with integrity and transparency in all business dealings and to implement effective systems and controls to ensure modern slavery is not taking place within our own business or any of our suppliers.

2. Scope

This policy applies to:

  • All employees, directors, and contractors of Kingston Trading (UK) Ltd;
  • All suppliers, distributors, subcontractors, and third parties acting on our behalf;
  • All business operations and trading names, including Kingston E-Liquids, Kingston Nic Pouches, Darwin CBD, and associated brands.

3. Our Business and Supply Chain

Kingston Trading (UK) Ltd is a UK-based manufacturer and distributor of e-liquids, nicotine pouches, and wellness products.
Our operations include:

  • Manufacturing and bottling of e-liquid products in the UK;
  • Packaging and distribution to retailers and wholesalers;
  • Sourcing raw materials, flavourings, and packaging components from trusted UK and international suppliers.

We maintain long-term relationships with reputable suppliers and expect all of them to uphold the same high ethical standards.

4. Our Commitments

We are committed to:

  • Ensuring all employees work voluntarily and are free to leave employment at any time;
  • Providing fair wages and safe, legal working conditions;
  • Verifying the identity, eligibility, and age of all workers;
  • Conducting due diligence checks on suppliers to ensure compliance with ethical standards;
  • Taking immediate action if modern slavery or exploitation is suspected.

5. Supplier Standards and Due Diligence

We expect all suppliers and partners to:

  • Comply with the Modern Slavery Act 2015 and local labour laws;
  • Maintain policies prohibiting forced labour, child labour, and human trafficking;
  • Provide transparent information about labour practices, recruitment, and working conditions;
  • Allow audits or assessments where required;
  • Notify Kingston Trading immediately of any suspected breach.

We reserve the right to terminate relationships with any supplier found to be involved in modern slavery or unethical practices.

6. Risk Assessment and Monitoring

While we primarily operate within the UK, we recognise that risks may exist in global supply chains — particularly where raw materials or components are sourced from regions with lower regulatory oversight.

To mitigate risk, Kingston Trading (UK) Ltd will:

  • Review and assess supplier risk annually;
  • Require supplier compliance declarations or codes of conduct;
  • Monitor procurement processes and perform spot checks where appropriate;
  • Encourage open communication channels for reporting concerns.

7. Training and Awareness

All employees, particularly those involved in procurement and supply chain management, will receive training on:

  • Recognising the signs of modern slavery and human trafficking;
  • Reporting mechanisms for concerns or suspected violations;
  • Ethical sourcing and responsible business practices.

This helps ensure that everyone in our organisation understands the importance of vigilance and due diligence.

8. Reporting Concerns

We encourage employees, suppliers, and third parties to report any concerns about potential modern slavery, human trafficking, or unethical practices.

Reports can be made confidentially to:
📧 sales@kingstoneliquids.co.uk
or directly to a member of senior management.

All reports will be taken seriously and investigated promptly.
No one will suffer retaliation for reporting a concern in good faith.

9. Continuous Improvement

Kingston Trading (UK) Ltd is committed to continuously improving our approach to combating modern slavery by:

  • Reviewing and updating this policy annually;
  • Enhancing supplier engagement and transparency;
  • Incorporating ethical standards into procurement procedures;
  • Publishing an annual statement (where required) in accordance with the Modern Slavery Act.