Big Potato Games is committed to respecting internationally recognised human rights across our operations and value chain.

This commitment is guided by the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the International Labour Organization (ILO) Core Conventions.

We recognise our responsibility to avoid infringing on human rights and to address adverse impacts with which we may be involved.

This commitment applies to:

• Our employees
• Workers across our supply chain
• Contractors and third-party partners
• Communities affected by our operations and business relationships

This Supplier Code of Ethics forms part of our broader approach to responsible business conduct and human rights due diligence.

This policy is publicly available and communicated to all relevant employees, suppliers, and partners.

Approved by Adam Wright, Co-CEO
Date: 22nd June 2026

This policy will be reviewed annually to ensure ongoing alignment with best practice and regulatory expectations.

1. Employment is freely chosen 

• We do not tolerate any forms of  forced, bonded, or involuntary labour
• Workers are not required to lodge "deposits" or their identity papers with their employer and are free to leave their employer after reasonable notice 
• Suppliers must not hold (for safekeeping), destroy, conceal, confiscate, or require workers to surrender government issued identification, passports, immigration documents, or work permits to any party, including third party agents. 

2. No child labour is used 

• Suppliers are required to engage workers who are: (i) at least 15 years old, (ii) the age of completion of compulsory education, or (iii) the minimum age to work in the country where work is performed, whichever is greater 
• Children and young persons under 18 shall not be employed at night or in hazardous conditions 
• Employers should implement an age verification system
• These policies and procedures shall conform to the provisions of the relevant ILO standards 

3. Living wages and benefits

• Wages and benefits paid for a standard working week must meet, at a minimum, national legal standards or wage set through collective bargaining agreement, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income 
• Suppliers are required to pay their workers, including contract workers and those paid by piece rate in a timely manner and provide overtime pay, benefits and paid leave
• Deductions in wages as a disciplinary measure are prohibited

4. Working hours

• Working hours must comply with national or local laws and regulations
• All overtime must be voluntary and paid in accordance with applicable laws and at a premium rate where required. 
• All terms and conditions of employment, including working hours should be documented in a written contract before staff enter employment
• Workers shall be provided with at least one day off in every seven-day period or, where allowed by national or local law, two days off in every 14-day period. 

5. Housing

Where suppliers provide or facilitate accommodation for workers, this must be managed to the highest standards of safety, dignity, and personal freedom. Accommodation must never be used as a means of control or influence over workers. 

• Accommodation must be entirely voluntary. Workers must have a genuine, penalty-free choice to live elsewhere without any impact on their employment, pay, or treatment. 
• Workers must be free to enter and leave accommodation at any time. Curfews, surveillance, restrictions on visitors, or any form of movement control are strictly prohibited. 
• Access to accommodation must not be linked to:
• Overtime expectations or additional working hours
• Job performance, seniority, or disciplinary status
• Continued employment (i.e. no risk of immediate eviction upon resignation)
• Workers must not be pressured, incentivised, or misled into using employer-provided housing. Recruitment processes must not present accommodation as a mandatory condition. 
• Any accommodation charges must be:
• Clearly communicated in advance
• Reasonable and not for profit
• Not result in workers earning below legal minimum wage after deductions
• Accommodation must meet all applicable legal standards and, at a minimum, provide:
• Adequate space, ventilation, lighting, and temperature control
• Clean and accessible sanitation and washing facilities
• Safe drinking water and hygienic food preparation areas (where applicable)
• Appropriate fire safety measures and emergency exits
• Secure, gender-appropriate, and private sleeping arrangements
• Additional safeguards must be in place for vulnerable groups (e.g. migrant workers, women, young workers), including protection from harassment, abuse, or exploitation 
• Suppliers must not retain passports, IDs, or personal belongings in connection with accommodation. 
• Workers must have access to safe, confidential channels to raise concerns about accommodation without fear of retaliation. 
• All accommodation arrangements must be disclosed and are subject to audit, inspection, and worker interviews. 
• Failure to meet these standards will be treated as a serious breach of the Code of Ethics and may result in corrective action requirements or termination of the business relationship 

6. Freedom of association and collective bargaining

• Suppliers must respect the rights of workers to join or form any labour unions to enable collective bargaining
• Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.

1. Provide a safe and healthy working environment

• All manufacturing sites producing product for Big Potato Games need to hold up to date fire and structural permits based on local laws
• Suppliers are required to provide workers  with free of charge personal protective equipment on any potential hazardous materials or machinery they may use
• Suppliers are required to provide appropriate machinery safeguarding and maintenance.
• Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers. 
• Workers must have reasonable and unrestricted access to basic hygiene facilities (e.g., handwashing stations, safe potable drinking water, clean toilet facilities, waste receptacles) 
• Suppliers are required to put in place procedures and systems to prevent, manage and report any workplace accidents or injuries
• The supplier should assign health and safety to a senior management representative

2. Anti discrimination, Respect & Dignity

• Suppliers should not discriminate in hiring, compensation, access to training, promotion, termination or retirement based on the basis of race, colour,  sex, gender identity, sexual orientation, religion, creed, the presence of any physical, sensory, or mental disabilities, age, political opinion, pregnancy, citizenship, migrant status, veteran status, ethnicity, ancestry, caste, marital or family status 
• Suppliers are prohibited from inquiring about a worker’s marital, pregnancy, or parental status as a criterion for hiring or continued employment 

1. Xinjiang Uyghur Autonomous Region (Uyghur Region) Sourcing Policy 

• Suppliers must not source any type of production and sourcing of any raw material linked to the exploitation and forced labour of Uyghur workers. Suppliers and factories must not source any service, directly or indirectly linked to the Uyghur region 
• All suppliers and factories must  be able to identify the source of the raw materials used in Big Potato products and to maintain records to prove its country and area of origin 

2. Wood based supply policy

• Big Potato requires that all wood-based products are sourced from responsibly managed forests, certified preferentially to the Forest Stewardship Council (FSC) and as minimum to the Programme for the Endorsement of Forest Certification (PEFC) certification system. 

3. Chemical policy

• Suppliers must ensure all products meet applicable safety standards with strict controls on inks, coatings, adhesives, and plastics. 

4. Traceability

• Suppliers must maintain clear oversight of the full supply chain, including approved subcontracts and critical component suppliers (e.g. printers, component manufacturers, packers)
• Suppliers must be able to provide evidence on request on the traceability of all raw materials used in the production of Big Potato products

5. Subcontracting

• Big Potato prohibits unauthorised subcontracting and requires full disclosure and approval of any third-party production. 

Big Potato recognises that suppliers vary in size, maturity and operating context. We expect all suppliers to meet applicable legal requirements and the mandatory provisions of this Code, while working towards the broader good practices described within it in a manner proportionate to their business.

1. Principles

• Suppliers should respect the right to a clean, healthy, and sustainable environment. Suppliers are required to comply with applicable environmental laws and regulations. 
• Suppliers should minimize adverse impacts on the environment, (including reducing the use of energy, air emissions, greenhouse gas emissions, waste, use of water, pollution, and hazardous materials). 
• Suppliers are encouraged to engage in efforts that support environmental sustainability, such as conducting environmental due diligence and making progress towards integrating environmentally sustainable practices throughout their operations and supply chain. 

2. Standards on Water, Waste, Air & Hazardous Substances

• Suppliers are required to obtain and keep current all necessary environmental permits, approvals, and registrations and follow applicable operational and reporting requirements. 
• Suppliers should continuously measure, record and track the amount of water used onsite, for both domestic and industrial processes, and from all sources including municipal mains, groundwater (boreholes and wells), and surface water (rivers, lakes).
• Suppliers should seek to reduce environmental impacts and, where possible set improvement targets 
• Suppliers should, where reasonably practicable, track and provide environmental usage data (including water, energy, hazardous substances, waste, and emissions) associated with the manufacture of Big Potato Games products to support impact assessment and continuous improvement initiatives. 
• Suppliers should continuously measure, record and track use of hazardous substances. Keep an inventory of all chemicals used, handled, transported and stored onsite, including their quantities and where they have been bought from. 
• Suppliers should take steps to reduce the use of hazardous substances and replace them with safer alternatives. Where possible, replace with safer, lower impact alternatives chemicals if they meet the same technical performance requirements. 
• Suppliers must dispose of hazardous waste safely and legally using licensed waste contractors only. 
• Suppliers are required to identify, routinely monitor, control, and treat air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting substances, and combustion by-products generated from operations as required by law prior to discharge 
• Suppliers should set targets to reduce emissions to air and start a programme to achieve the reduction. 

Big Potato believes responsible sourcing is best achieved through long-term partnerships built on openness, trust and continuous improvement. We will work collaboratively with suppliers to understand risks, share good practice and support improvements where appropriate. To do this we reserve the right to:

• Request Information and Documentation
  Request relevant information from suppliers relating to labour practices, working conditions, subcontracting, and supply chain transparency.
• Conduct Audits and Assessments
  Undertake periodic announced or unannounced audits, as well as ad hoc assessments, either directly or through third-party auditors, where appropriate.
• Verify Supply Chain Transparency
  Require full disclosure of manufacturing locations, subcontractors, and any third-party involvement in production.
• Engage in Corrective Action Processes
  Work collaboratively with suppliers to investigate, address, and remediate any issues identified, including the implementation of corrective action plans within agreed timeframes.
• Monitor Ongoing Compliance
  Track supplier performance over time and require evidence of continuous improvement where risks or non-compliances have been identified.
• Enforce Accountability
  Big Potato is committed to working with you to rectify any non compliance, however if action is not taken to resolve  cases of non-compliance, this may result in suspension of orders, or termination of the business relationship.

We are committed to operating responsibly, ethically, and transparently across our business and supply chain. We encourage external stakeholders to raise concerns where our practices, products, partnerships, or operations may fall short of these expectations.

Your privacy matters. We treat all reports confidentially and will not tolerate retaliation against anyone who raises a genuine concern in good faith.

Contact us at: reportaconcern@bigpotato.co.uk
Or via the Report a Concern at bigpotato.com 
Or via post marked ‘Confidential’ to the CEO at Big Potato Games, 2nd Floor, 63 Gee St, London, EC1V 3RS.

As part of onboarding and our ongoing partnership, suppliers are required to acknowledge this Code of Ethics. By signing below, suppliers confirm that they have read and understood the expectations set out in this Code and will work in good faith to comply with its principles. Where full compliance has not yet been achieved, suppliers agree to be transparent about any gaps and to work collaboratively with Big Potato on appropriate improvement actions.

As part of our partnership with Big Potato, we confirm that:

☐ We have read and understood this Code.

☐ We are committed to meeting its requirements.

☐ We will notify Big Potato of any material breaches or significant changes.

☐ We will be open about areas where improvements are still required.

☐ We will work collaboratively with Big Potato to agree reasonable improvement actions where appropriate.

Signed

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