1. POLICY STATEMENT

1.1. Forests play a critical role in climate change mitigation, provide an invaluable habitat for wildlife, and support the livelihoods of many people around the world.

1.2. In line with our commitment to Net Zero 2040, we are committed to ensuring deforestation-free products and supporting the prevention of illegal deforestation across our supply chains by 2040. However, due to the European Union Deforestation Regulations (EUDR), many of our products will be required to be deforestation-free by 2026. We are committed to ensuring products that will be exported to the EU are EUDR compliant (see Appendix 1).

1.3. ‘Deforestation-free’ means:
(a) that the relevant products contain, have been fed with or have been made using raw materials, referred to as ‘in-scope materials’ (see Appendix 1), that were produced on land that has not been subject to deforestation after December 31, 2020, and
(b) in the case of relevant products that contain or have been made using wood, that the wood has been harvested from the forest without inducing forest degradation or negatively impacting biodiversity after December 31, 2020.

This applies also to products exported to the EU, but where we are committed to procuring deforestation-free products by 2030, exports to the EU are required to be compliant by 2026.

1.4. This policy is closely linked to other policies already in place, including:
• Environmental Policy Statement
• Palm Oil Policy

2. RESPONSIBILITY FOR THE POLICY

2.1. The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

2.2. The compliance manager for deforestation prevention is the Sustainability Manager who, with support from the Operations Director and the Managing Director, has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering deforestation.

2.3. All employees must read, understand, and comply with this policy. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

3. OUR COMMITMENTS

3.1. To enforce our commitment to procure deforestation-free products and prevent illegal deforestation across our supply chain, in line with our Net Zero by 2040 strategy and EUDR legislation we:

3.1.1. Commit to continue to do the following:

• Ensure there is board-level oversight of forest-related issues.
• Ensure this policy is made available company-wide.
• Ensure this policy is made publicly available and commits to deforestation-free activities by 2030.
• Ensure that we procure deforestation-free products for EU export by 2026, in line with EUDR legislation.
• Ensure this policy is fully integrated into the strategic Net Zero by 2040 plan.
• Where products contain in-scope raw materials, ensure these come from certified sources (see Appendix 2). Certification plays a key role in helping producers transition to more sustainable farming practices which support sustainable production and reduce deforestation.
• Proactively assist smallholder coffee suppliers in preserving biodiversity and encourage reforestation through specific programmes. For example, we have previously supported reforestation projects in Bolivia with the Asocafé cooperative and in Peru with the San Juan del Oro cooperative. Further information on these programmes can be found in our Sustainability Reports. We will use data from our annual producer surveys and work with stakeholders to most effectively direct resources for future projects.

3.1.2. Commit to the following, as recommended by the Accountability Framework Initiative:

• Conduct a comprehensive deforestation risk assessment with clear goals and outcomes.
• Ensure we can trace 100% of non-EU export supplier production/consumption back to at least municipality or equivalent.
• Ensure we can trace 100% of EU export supplier production/consumption back to the exact geolocation.
• Ensure 100% of in-scope materials are certified in a no-deforestation compliant certification.
• Ensure we support and improve supplier capacity to comply with forest-related policies, commitments and other requirements through financial or technical assistance.
• Work beyond first-tier suppliers to manage and mitigate deforestation risks through supply chain mapping or capacity building.
• Work with smallholders to support good agricultural practices and reduce deforestation or conversion of natural ecosystems through financial or technical assistance.
• Control, monitor and verify compliance with no-deforestation policies and commitments across all relevant operations and supply chains with 100% of total volume in compliance.
• Assess company or supplier compliance with forest regulations and/or mandatory standards if sourcing from high-risk regions.
• Support or implement ecosystem restoration and protection projects with timely monitoring and measured outcomes.

4. COMMUNICATION AND AWARENESS OF THE POLICY

4.1. All employees are made aware of this policy as part of their induction.

4.2. Adequate information and training on the prevention of deforestation is made available to all employees, with priority given to those with responsibility for procuring forest-risk commodities.

4.3. Our approach to preventing deforestation in supply chains is communicated to suppliers, contractors and business partners at the outset of our business relationship and reinforced as appropriate thereafter.

5. BREACHES OF THIS POLICY

5.1. The prevention, detection and reporting of deforestation in our supply chains is the responsibility of all those working for us who engage with our suppliers and have responsibility for purchasing decisions. These employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

5.2. Employees are encouraged to raise concerns about deforestation in our supply chains (of any supplier tier) at the earliest possible stage. This includes when they suspect that an instance of deforestation has occurred or may occur in the future.

5.3. Where a supplier has breached or may breach the standards set out in this policy, the matter should be reported to the line manager and the Compliance Manager for follow-up. We reserve the right to terminate our relationship with suppliers or organisations working on our behalf if they breach this policy.

Endorsed: Nick Snow – Managing Director
Date: 10/01/2025
Endorsed: Neil Freckingham – Operations Director
Date: 10/01/2025

Appendix 1: European Union Deforestation Regulations and Affected Materials

The following commodities and product categories fall within the scope of the EUDR legislation:

Cattle: Live cattle; beef (fresh, chilled or frozen); edible offal; preserved meat; blood products; raw hides and skins; tanned leather.
Cocoa: Whole cocoa beans; husks; paste; butter; cocoa powder; chocolate; other cocoa-containing foods.
Coffee: Green coffee; roasted coffee; coffee husks and skins; coffee substitutes.
Oil Palm: Palm nuts and kernels; palm oil and fractions; palm kernel oil; babassu oil; oilcake and residues; palmitic acid; fatty acids; industrial fatty alcohols.
Rubber: Natural rubber; balata; gutta-percha; chicle and similar gums; compounded, unvulcanised and vulcanised rubber; belts; tyres; inner tubes; apparel and accessories; hard rubber goods.
Soya: Soya beans; flour; meal; soya oil and fractions; oilcake; solid residues.
Wood: Fuel wood; charcoal; lumber; wood wool; fibreboard; plywood; densified wood; frames; cases (excluding packing material used exclusively for protecting goods); tools; joinery; tableware; books; newspapers; seats.

Note: Annex I of the EUDR legislation states that wood products do not include packing material used exclusively to support, protect or carry another product placed on the market.

Appendix 2: Raw “In-Scope” Materials for Non-EU Exports

Coffee: Primary materials – Coffee beans. Secondary materials – Coffee used as an ingredient.
Cocoa: Primary – Cocoa butter, cocoa powder, cocoa liquor. Secondary – Cocoa used as an ingredient.
Palm Oil: Primary – Crude palm oil, palm kernel oil, PFAD, fatty alcohols. Secondary – Palm oil used as an ingredient.
Pulp and Paper: Primary – Wood-fibre derived packaging. Secondary – Labels, tea bags.
Soy: Primary – Soybean oil, soy protein. Secondary – Soy products not derived from oil (e.g., lecithin) and embedded soy used in animal feed.
Tea: Primary – Leaf tea. Secondary – None.
Timber: Primary – Wood prepared for use. Secondary – Timber used in equipment such as pallets.
Sugar: Primary – Cane sugar. Secondary – Sugar used as an ingredient.
Metals: Primary – Steel, copper, lithium, tin, silver, gold, nickel, aluminium etc. Secondary – Metals used in coffee machines, electronics and factory equipment.
Natural Rubber: Primary – Natural rubber. Secondary – Rubber used in equipment and machines.
Cattle: Primary – Leather. Secondary – None.

Appendix 3: Certification Regulations for Deforestation

Below is the table content rewritten into paragraph form while keeping all wording exactly as provided:

Fairtrade (Coffee, Cocoa):
Fairtrade Standard for Small-scale Producer Organisations (requirements 3.2.31 and 3.2.32).
Fairtrade actively promotes the protection of forests and the planting of trees. Fairtrade Standards prohibit the felling of forests with high conservation value and require cooperatives to map risk areas, raise climate awareness and promote climate-friendly production methods.

Rainforest Alliance (Coffee, Cocoa):
Sustainable Agriculture Standard – Farm Requirements (requirements 6.1, 6.2 and 6.4).
The standard focuses on natural climate solutions, including forest conservation, restoration and improved land management to increase carbon storage, avoid emissions and build resilience to climate change.

RSPO – Round Table on Sustainable Palm Oil (Palm Oil):
RSPO Principles and Criteria (criteria 7.12).
Legality is a requirement for RSPO-certified production, making RSPO certification a viable tool for due diligence related to illegal deforestation.

FSC – Forest Stewardship Council (Pulp and Paper):
FSC National Forest Stewardship Standard of the UK (indicators 6.9.1, 6.9.2 and 6.9.3).
FSC does not allow deforestation within certified concessions and requires forest managers to maintain or enhance forest cover, structure, biodiversity and productivity.

RTRS – Round Table on Responsible Soy (Soy):
RTRS Standard for Responsible Soy Production (guidance principles 4.4 and 4.5).
RTRS includes zero-deforestation and zero-conversion criteria, prohibiting conversion of natural land, steep slopes or protected areas.

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