MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

 

Introduction

The Modern Slavery Act 2015 requires certain organisations to state the actions they have taken during the financial year to ensure modern slavery and human trafficking are not taking place in their operations and supply chains. This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes Green Man Gaming’s slavery and human trafficking statement for the financial year ending 5th April 2026.

We are committed to preventing and eliminating acts of modern slavery and human trafficking within our business and our supply chains. This statement sets out the actions taken by Green Man Gaming to prevent potential modern slavery and human trafficking risks related to our business and refers to actions and activities during the financial year ending 5th April 2026. As part of the technology and video game industry, the organisation recognises that it has a responsibility to take a robust approach to modern slavery and human trafficking.

Organisation structure and supply chains

Green Man Gaming is a global e-commerce business, with headquarters in the United Kingdom, and operating in a remote setting. We sell digital video games to customers in 195 countries around the world through our e-commerce website and work with independent game developers to publish their games. We also partner with leading hardware manufacturers, game retailers and publishers on marketing initiatives, as well as other corporate and business partners.

Our supply chain primarily consists of digital content providers (game publishers and developers), marketing and technology service providers, and corporate partners. While our operations are predominantly digital, we recognise that elements of our extended supply chain may operate in higher-risk jurisdictions.

Policies in relation to modern slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business. This statement 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 modern slavery and human trafficking are not taking place anywhere within our corporate activities. The organisation's code of conduct makes clear to employees of the actions and behaviours expected of them when representing the organisation. The following policies are available to all staff: Whistleblowing, Health & Safety, Equality, Diversity and Inclusion, Bullying and Harassment.

Due diligence processes

Due to the nature of our business, which is primarily digital, we consider the risk of modern slavery within our direct operations to be relatively low. We foster a culture that encourages the identification and reporting of any such risks within our business. We mainly recruit our employees directly without involvement of third-party recruitment agencies. If external support is required on infrequent occasions, the organisation only uses specific, reputable employment agencies that are verified before engaging them. We undertake due diligence on our supply chain and business partners, which includes assessments at onboarding, verification of supplier legitimacy, and consideration of geographic and sector risk indicators.

Risk assessment and management

The organisation encourages all its staff, customers and other business partners to report any concerns related to direct activities, or the company’s supply chains to the organisation. We have a whistleblowing policy in place that helps to identify, assess and mitigate risk areas within our business. The organisation's whistleblowing procedure is designed to make it easy for staff members to make disclosures, without fear of retaliation. We continue to review our risk exposure periodically, taking into account the geographic reach of our partners and the nature of services provided, and will enhance our processes as our business evolves.

Effectiveness in tackling modern slavery and human trafficking

We have zero tolerance to slavery and human trafficking. Where possible, we work with our suppliers and business partners to ensure they have a modern slavery and human trafficking policy in place and that they require the same from their suppliers. Green Man Gaming’s expectation is that the supply chain adheres to equivalent standards.

Training

All new employees are required to undertake training about the company’s culture, values and policies. During the induction process we cover this along with sharing our company policies and ensuring that all new employees read and understand the key policies and our commitment to our company values and behaviours. We aim to enhance awareness of modern slavery risks by incorporating relevant guidance into onboarding and internal communications, and will consider more formal training for relevant employees as appropriate.

This statement has been approved by the Board of Directors and signed by Paul Sulyok, Founder & CEO on 9th April 2026. The statement will be reviewed and updated every year.