1. Scope

This policy applies to all Star Linen UK Ltd (“Star Linen”, “SLUK”) employees and through our Code of Conduct, extends to suppliers, contractors and other partners working on behalf of, or in the supply chain of, the company. It sits alongside and is supported by our Code of Ethics Policy, Code of Conduct Policy, Equity, Diversity and Inclusion (ED&I) Policy, Diversity & Inclusion Policy, Equal Opportunities and Harassment Policy, Human Trafficking and Modern Slavery statement and ESG Policy.

2. Policy statement

Star Linen UK Ltd is committed to respecting human rights across our own operations and throughout our supply chain. We recognise that our business, sourcing, manufacturing, moving and supplying linen and bedding products to the hospitality sector, can affect the people who work within it and we take that responsibility seriously as part of the Star Way and our B Corp commitments.

In carrying out this commitment, we align our approach with the following internationally recognised human rights frameworks:

a) UN Guiding Principles on Business and Human Rights

We seek to identify, prevent, mitigate and account for actual and potential human rights impacts connected to our business activities, products and supply chain and to provide or cooperate in remedy where our activities have caused or contributed to harm.

b) The International Bill of Human Rights, including the Universal Declaration of Human Rights

We uphold the principles of human dignity, equality and non-discrimination, freedom from forced or compulsory labour and fair and safe working conditions, reflected in our Code of Conduct, Human Trafficking and Modern Slavery statement and Equity, Diversity and Inclusion policies.

c) The International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work

We support freedom of association and the right to collective bargaining, the elimination of all forms of forced or compulsory labour, the effective abolition of child labour and the elimination of discrimination in respect of employment and occupation, standards we require of ourselves and of our suppliers.

3. Our commitments

Our people

• We provide safe, fair and inclusive working conditions, free from discrimination, harassment, bullying and victimisation, as set out in our ED&I, Diversity & Inclusion and Equal Opportunities and Harassment policies.

• We pay at least the minimum wage required by law and are committed to fair pay practices reviewed regularly for equity.

• We provide accessible, confidential routes for employees to raise concerns without fear of retaliation, with matters investigated promptly and fairly.

• We support employee wellbeing, including mental health support, training and development and reasonable adjustments for disabled employees and candidates.

Our supply chain

• We require all suppliers to comply with our Code of Conduct, which prohibits underage labour, forced and bonded labour and human trafficking and sets clear expectations on wages, working hours, health and safety, non-discrimination and grievance mechanisms.

• We require suppliers to complete a BSCI audit, or an equivalent independent audit of the country of production, as part of supplier onboarding and ongoing review.

• We prioritise suppliers who demonstrate strong labour and environmental standards and who are transparent about their practices and we are developing more structured supplier engagement, including periodic reviews and clearer codes of conduct.

• We consider the actual and potential human rights impacts of our most material procurement decisions, both when a decision is first made and on an ongoing basis, informed by audits, supplier engagement and our Code of Conduct requirements.

Grievance and remedy

• Star Linen provides accessible ways for workers, suppliers and other stakeholders to raise human rights concerns or grievances, in line with our grievance procedure.

• Grievances are handled confidentially, without retaliation and with a clear route to investigation, resolution and, where appropriate, remedy.

• Our Code of Conduct requires suppliers to provide their own workers with an accessible, transparent grievance mechanism, available in workers’ native languages where relevant.

4. Governance and responsibility

• This Human Rights Policy is owned and approved by Stephen Broadhurst, Managing Director, as the highest governing body for this purpose at Star Linen UK Ltd.

• The policy is reviewed at least annually as part of the company’s ESG and B Corp governance process, alongside the Impact Report, Code of Conduct and related policies and updated to reflect changes in law, best practice or business operations.

• Day-to-day implementation is supported by relevant functional owners, including HR (people-related commitments) and procurement/supply chain leads (supplier-related commitments).

5. Monitoring and review

• We monitor implementation of this policy through supplier audits, employee feedback mechanisms, grievance records and our annual Impact Report.

• Any material human rights risks or incidents identified are reported to the Managing Director and leadership team, with corrective actions tracked to completion.

• This policy will next be reviewed no later than January 2027, or sooner if required by changes in legislation, customer expectations or business operations.

6. Related legislation and frameworks

This policy is guided by and complies with:

• UN Guiding Principles on Business and Human Rights.

• The International Bill of Human Rights / Universal Declaration of Human Rights.

• The International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work.

• Human Rights Act 1998.

• Modern Slavery Act 2015.

• Equality Act 2010.

• Employment Rights Act 1996.

1. Purpose

This policy sets out how Star Linen UK enables workers, customers, suppliers, community members and any other stakeholder to raise a grievance or serious concern about the company’s actions, decisions or omissions, and how the company receives, investigates, resolves and learns from grievances. It supports Star Linen UK’s B Corp commitments to fair, safe and ethical treatment of all stakeholders and to transparent, accountable governance.

2. Policy Objectives

• Provide an easily accessible, confidential and non-retaliatory way for any stakeholder to raise a grievance.

• Ensure every grievance is acknowledged, assessed and investigated within clear, published timeframes.

• Give complainants a fair hearing and keep them informed throughout the process.

• Record, monitor and review grievances so that trends and systemic issues inform improvements to policy, training and controls.

• Assign clear ownership for managing the grievance process and reporting on it to leadership.

3. Scope: Who Can Raise a Grievance

This policy applies to grievances raised by any of Star Linen UK’s stakeholders, including:

•  Employees of Star Linen UK or its subsidiaries.

• Customers.

• Suppliers.

• Owners.

• Community members local to Star Linen UK’s offices, facilities or supply chain.

• Any other stakeholder affected by Star Linen UK’s operations, products or services.

4. What Counts as a Grievance

A grievance may be raised when a stakeholder believes that Star Linen UK’s actions, decisions or omissions have caused, or may cause:

• A breach of company policies or codes of conduct.

• Unfair or unsafe treatment of workers, customers or suppliers, including workplace conditions.

• Product quality or safety concerns.

• Negative environmental or social impacts linked to the company’s operations, products or supply chain.

• Behaviour that is unethical, discriminatory, harassing, unsafe or inconsistent with Star Linen UK’s B Corp and sustainability commitments.

5. How to Raise a Grievance

Star Linen UK provides an easily accessible route for any stakeholder to raise a grievance, without requiring them to have a pre-existing relationship or account with the company:

• Online form: the "Grievance and Concern Submission" form at star-linen.co.uk/pages/stakeholder-comment.

• Phone: 01443 80 50 50 (Monday to Friday, 9am–5pm).

• Email: info@star-linen.co.uk.

• In writing: Star Linen, Unit 1, Withey Dyffryn Court, Dyffryn Business Park, Ystrad Mynach, CF82 7TT.

Information about how to raise a grievance is published on the company website and referenced in relevant internal policies, so that workers, customers, suppliers and community members know how to raise a concern.

6. Grievance Process and Timeframes

Once a grievance is received, Star Linen UK follows these steps and target deadlines:

1.  Acknowledgement – we acknowledge receipt within 3 working days.

2.  Initial assessment – we complete an initial assessment within 10 working days of acknowledgement, to confirm whether the
issue will be treated as a grievance under this policy and whether any immediate action is required.

3.  Investigation – where a full investigation is needed, we gather information from the complainant and any relevant documents, systems or individuals.

4.  Outcome – we aim to provide an outcome within 30 working days of acknowledgement. If the matter is complex and takes longer, we keep the complainant updated on progress and revised timeframes.

5.  Closure and follow-up – we confirm the outcome in writing, record it in the grievance register and, where appropriate, monitor any agreed follow-up actions.

7. Resolution and Escalation

Grievances are facilitated by the General Manager, or another manager designated for a specific case to ensure independence – for example where the General Manager has a direct connection to the matter raised. The aim is to resolve issues as close as possible to the point at which they arise.

Resolution options may include corrective action, changes to practices or policies, remedial support to affected stakeholders and, where appropriate, escalation to the Managing Director and leadership team for oversight.

8. Confidentiality and Protection from Retaliation

Information provided as part of a grievance is shared only with those who need it to assess and manage the case. Access to grievance records is limited to authorised personnel.

Star Linen UK does not tolerate retaliation of any kind against a stakeholder who raises a grievance in good faith. A stakeholder may raise a grievance anonymously if they prefer, although this may limit the company’s ability to investigate fully. Any suspected retaliation is treated as a separate disciplinary matter and may result in corrective action.

9. Communication with Complainants

Star Linen UK responds to every grievance by either:

• regularly communicating the status of the investigation and each significant step in the resolution process, and confirming in writing when the grievance has been resolved and closed; or

• explaining clearly and respectfully why an issue has not been accepted as a grievance, and signposting alternative routes for feedback or escalation.

10. Monitoring, Recording and Reporting

Star Linen UK maintains a grievance register recording, for every grievance received: the date, stakeholder category, subject, status, outcome and any remedial action taken.

The register is reviewed at least annually to prepare a summary of the number, type and status of grievances and to identify any trends or systemic issues. Insights from this review are used to improve policies, training and controls, and are reported to the Managing Director and leadership team as part of the annual governance review (see the B Corp Purpose & Stakeholder Governance 5.1 review).

Where no grievances are received in a given period, Star Linen UK retains evidence that this policy, the register and the reporting mechanisms described here remain in place and ready to record and manage a grievance if one arises.

11. Roles and Responsibilities

General Manager

Owns this policy day to day: receives and triages grievances, coordinates investigations, maintains the grievance register, and reports a summary to the Managing Director and leadership team at least annually.

Managing Director and leadership team

Provide oversight and escalation for complex or high-risk grievances; review the annual grievance summary as part of the annual governance review; approve any changes to this policy.

All employees

Treat every grievance raised under this policy seriously, confidentially and without retaliation and escalate any grievance received informally to the General Manager.

12. Policy Review

This policy is reviewed at least annually, or sooner if the grievance process changes materially, as part of Star Linen UK’s annual Purpose & Stakeholder Governance review. Changes are approved by the Managing Director and leadership team and recorded in meeting notes or minutes.

13. Compliance

All employees are expected to comply with this policy as part of Star Linen UK’s commitment to fair, transparent and accountable business practice. Failure to handle a grievance in line with this policy, or any act of retaliation against a person who raises a grievance in good faith, may be treated as a disciplinary matter.

Star Linen UK Ltd does not engage in lobbying activities, either directly or through trade associations, industry bodies, or intermediary organisations, on its own behalf or on behalf of others. This position is reviewed periodically as part of the company's ESG governance process and will be published on the company's website, with any change to this position updated publicly.

Star Linen UK exists to improve comfort and wellbeing across the hospitality, leisure and education sectors while reducing the environmental and social footprint of linen.

The company’s purpose is to ensure the world sleeps better, dines better and enjoys greater comfort by providing quality bed linen and bedding that are produced, transported and managed in ways that minimise carbon emissions, cut waste and support fair, safe working conditions throughout the value chain.

This purpose is embedded in Star Linen UK's business strategy through its focus on supplying durable, high-quality products, investing in circular initiatives such as the not-for-profit ReStart programme for old bedding take-back and repurposing and our new Avena partnership for zero-to-landfill towel and bed linen re-purposing, partnering with low-carbon logistics providers and maintaining Carbon Neutral certification.

Commercial decisions on product development, supplier selection, logistics and customer partnerships are evaluated against the company’s commitments to B Corp principles, carbon reduction, waste diversion and responsible sourcing.

The company’s purpose statement and its integration into strategy are reviewed and approved by the Managing Director and senior leadership team at least once every 12 months as part of the annual business and sustainability planning process.

The Managing Director and senior leadership team confirm that commercial plans, investment priorities and key initiatives remain aligned with Star Linen UK’s stated purpose and B Corp commitments and any changes to the purpose wording or its application are formally agreed and minuted.