Modern Slavery Statement 2025

Preamble

GSLT Holdings Limited is the parent company of the Palace Skateboards group (“Group” or “Palace”).

This statement has been published in accordance with the Modern Slavery Act 2015. The Group’s previous Modern Slavery statement was published on 11 July 2024, and related to the period 1 February 2022 to 31 January 2023 (the “FY23 Statement”). This Statement is published on 31 July 2025 and relates to the period 1 February 2024 to 31 January 2025 (the “Period”), which aligns with our financial reporting year.

Introduction from Gareth Skewis, CEO and Lev Tanju, Creative Director of the Palace Skateboards Group

It is important to us and everybody at Palace that our products are produced by people that enjoy the fundamental rights of being treated with dignity and respect, and are not deprived of their liberty through exploitation. Palace has zero tolerance of any modern slavery or human trafficking violations.

We have close relationships with a number of Palace’s long-term suppliers and continue to strengthen those relationships as we continue to grow. However, we are also aware that apparel supply chains are long and complex, so we do not always have direct relationships or knowledge of every facility that contributes to the production of our goods.

We believe in promoting human rights throughout our business and our supply chain and are committed to improving our practices and putting in place formal systems to combat modern slavery and human trafficking. We are still in the early stages of this work and hope to continually make progress each year.

Our business

Palace is a skateboarding and fashion brand that designs, develops, and retails clothing, footwear, accessories and skateboards. The Group has approximately 130 employees worldwide, including 60 in our London head office, plus operations in the UK, US, Europe and Japan.

Our co-branded projects are an integral part of our business and as such we choose our partners very carefully. Our co-branded partners are reputable businesses who are responsible for their supply chains, and are required to provide Palace with appropriate visibility and assurances.

During the Period, we had five retail stores around the world, in London (UK), New York City (USA), Los Angeles (USA), Tokyo (Japan), and Seoul (Korea).

The Group runs its own fulfilment and warehousing in London (UK) and New Jersey (USA), and outsources similar operations to a third party in the Netherlands, Japan and in Korea.

Our employees are key to Palace and its success and we do our utmost to ensure that they are well looked after and fairly treated. We have engaged human resource advisors in every territory where we have direct employees to ensure that we comply with local laws and regulations.

We believe that the right to health care is a fundamental right so provide health care insurance for our employees in the US and Japan, and access to private health care insurance in the UK and Europe.

Policies Relating to Slavery and Human Trafficking

We are committed to the principle of ensuring that there is no modern slavery or human trafficking in our supply chains or any part of our business. Our Anti-slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place in our supply chains.

To further ensure our ethics and values are shared by the facilities that directly make our finished goods (our “Tier 1 Factories”) and the businesses that coordinate the production of our finished goods through Tier 1 Factories (our “suppliers”), Palace requires them to adhere to our Ethical Code of Conduct (the “Code”) which is based on the Ethical Trade Initiatives (ETI) Base Code available here. The Code sets out the minimum working conditions and ethical standards we require. It is built on the conventions of the International Labour Organisation (ILO) and contains the foundations for fair labour practices. We require all new suppliers and Tier 1 factories to adhere to The Code and for all our existing suppliers and Tier 1 Factories to reconfirm their adherence every two years and ensure these standards are implemented within their own operations and throughout their supply chain.

Risk Assessment and Due Diligence

As is typical in the fashion industry, our product supply chain poses the biggest risk of modern slavery and trafficking within our business. As such, during the Period we have continued to concentrate on mapping our Tier 1 Factories, and their modern slavery and ethical compliance.

Social audits are an important part of both risk assessment and due diligence. During the Period, Palace has increased the number of its Tier 1 Factories that have completed and provided an independent third-party social audit in line with the Code and our requirements - from 90% to 96%. We continue to work with the outstanding suppliers to complete this work.

Palace has a rigorous onboarding process in all our commercial agreements with third parties and co-branded partners to ensure that the suppliers that they work with are compliant with our Code as a minimum. This process is under ongoing review and continuous improvement.

An integral part of our production team’s role is regular visits to our suppliers and Tier 1 Factories around the world, to not only discuss orders but to build relationships and monitor social compliance. During the Period, members of the Palace team have spent over 5 weeks visiting our key factories in Vietnam, ChinaHong Kong and Korea to maintain and foster transparent relationships with our suppliers.

Palace is aware that incidences of slavery and trafficking can also occur closer to home. We have a network of suppliers supporting the operations of our business, including logistics, transport, and delivery. Our warehouse in London and our main warehouse in the US are operated by the Group and staffed by direct employees – when additional temporary workers are required, they are hired through reputable agencies. Our warehouses in the Netherlands and Japan are run by well-regarded third parties and adhere to decent working and employment practices.

Review and Next Steps

We can confirm that Palace has received no reports or incidents of modern slavery or human trafficking in our supply chains during the Period.

As Palace grows as a business, we are committed to acknowledging our responsibility as a brand, and continue to challenge our policies, supplier mapping, and improve our supply chain transparency, and develop our social compliance goals.

We committed to carrying out the following steps during the Period and will continue to build on these goals over the next year:

Continue to map our Tier 1 Factories as our supplier base grows Supplement our commercial agreements with third parties to ensure they are required to comply with our anti-slavery and human trafficking policy and the Code. As and when required, we will continue to work with external specialists as required to assess our supply chain risk, map our Tier 1 Factories and review their compliance standards. We have implemented a rigorous onboarding process in all our commercial agreements with third parties and co-branded partners to ensure that the suppliers that they work with are compliant with our Code as a minimum.

GOAL FOR FY2026
During the next period we will continue our efforts to increase the % of Tier 1 Factories that are audited to support their compliance with the Code

Continue to monitor, evaluate and review our suppliers and ensure they comply with our anti- slavery and human trafficking policy.

We have made no changes to our anti-slavery and human trafficking policy during the Period. We have merged our modern slavery supplier questionnaire with our new supplier onboarding questionnaire to minimise the paperwork our suppliers need to complete, whilst ensuring compliance is addressed from the outset of our relationships.

GOAL FOR FY2026
We will continue to review our anti-slavery and human trafficking policy and supplier onboarding questionnaire to ensure they remain robust and relevant.

Extend our training programme throughout our business to alert all of our employees, in particular our supplier facing employees to the risks of Modern Slavery.

Online training in relation to Modern Slavery and an understanding of the steps that can be taken to reduce the risk of modern slavery in our supply chains.

In this Period, we have included this training as part of the induction programme for all new starters.

GOAL FOR FY2026 We will continue to ensure that all new employees take this training as part of their induction and all existing employees will be required to take this training every two years.

Board approval

This statement was approved by the board of GSLT Holdings Limited.