1. PUBLISHING NOTE

This statement is voluntary. The UK Modern Slavery Act 2015, Section 54, requires annual modern slavery statements from commercial organisations with UK nexus and annual turnover of £36 million or above. Baghpat House Exports Private Limited is below that threshold and has no legal obligation under the Act.

We publish because: (a) our European wholesale buyers conduct supply-chain due diligence under their own obligations, including under the EU Corporate Sustainability Due Diligence Directive (Directive 2024/1760, as amended by Directive (EU) 2026/470); (b) the EU Forced Labour Regulation (Regulation (EU) 2024/3015), applicable from 14 December 2027, will prohibit products made with forced labour from entry to the EU market regardless of the size of the exporter; and (c) transparency is consistent with how we operate.

This statement covers the financial year 1 April 2025 to 31 March 2026.

2. ABOUT BAGHPAT HOUSE

Baghpat House Exports Private Limited (trading as Baghpat House) is a registered Indian private limited company and manufacturer of handcrafted natural-fibre and leather goods. The company was incorporated under the Companies Act, 2013 on 24 June 2024.

2.1 Company Identification

2.2 Products and Markets

We manufacture bags, baskets, home accessories, and leather goods from Raffia, Rattan, Water Hyacinth, Palm Leaf, Kauna Grass, Bamboo, and full-grain leather. Our products are exported to wholesale and retail buyers in Europe and the United Kingdom through direct buyer relationships and B2B wholesale platforms.

2.3 Export and Tax Status

We hold an Import Export Code (IEC: AAMCB7066N) issued by the Directorate General of Foreign Trade on 29 July 2025. Our exports are zero-rated under Section 16 of the IGST Act, 2017. We export under a Letter of Undertaking (Form GST RFD-11), renewed annually, enabling export without upfront IGST payment. Export proceeds are realised and repatriated in convertible foreign exchange through our Authorised Dealer bank within 9 months of shipment, as required under the Foreign Exchange Management Act, 1999 (FEMA).

2.4 MSME Status

We are a Micro Enterprise under the Micro, Small and Medium Enterprises Development Act, 2006 (MSMED Act), classified under NIC code 15121. As a Micro Enterprise, we are entitled to benefits under the MSMED Act including the MSME Samadhaan portal for recovery of overdue domestic payments, where buyers who fail to pay within 45 days of acceptance of goods are liable to compound interest at three times the bank rate.

2.5 E-Commerce Compliance

When selling through e-commerce platforms (whether B2B wholesale platforms or B2C marketplaces), we comply with the Consumer Protection (E-Commerce) Rules, 2020 notified under the Consumer Protection Act, 2019. This includes providing accurate product descriptions, country of origin disclosure (India), clear return and refund policies, and appointing a grievance officer where required. We do not engage in unfair trade practices, post fraudulent reviews, or misrepresent product features.

2.6 Workforce

We employ workers at our Gurugram manufacturing facility. We also engage home-based artisan households for weaving and natural-fibre work on a piece-rate basis.

3. GOVERNANCE

Responsibility for this statement rests with the Board of Directors of Baghpat House Exports Private Limited.

Statutory Directors (per MCA records):

Reena Nain (DIN 07201715) — Director; also serving as Chairperson and Managing Director per Board resolution

Vishal Nain (DIN 10680541) — Director; also serving as Chief Operating Officer per Board resolution

Executive Management:

Dhananjay Chaudhary — Chief Executive Officer (appointed by the Board)

Day-to-day responsibility for workforce compliance and artisan relationships is managed by Reena Nain.

This statement was approved by the Board and will be reviewed annually.

4. INTERNATIONAL STANDARDS FRAMEWORK

Our approach is guided by the following international instruments:

• ILO Core Labour Standards (Conventions 29, 87, 98, 100, 105, 111, 138, and 182) — covering freedom of association, collective bargaining, elimination of forced and compulsory labour, elimination of child labour, and non-discrimination in employment

• UN Guiding Principles on Business and Human Rights (UNGPs, 2011)

• OECD Due Diligence Guidance for Responsible Business Conduct (2018)

• Universal Declaration of Human Rights (UDHR, 1948)

• ILO Forced Labour Convention, 1930 (No. 29) and its 2014 Protocol

• ILO Worst Forms of Child Labour Convention, 1999 (No. 182)

We also align with the due diligence expectations that will reach us through our European buyers under: the EU Corporate Sustainability Due Diligence Directive (CSDDD, Directive 2024/1760, as amended by the Omnibus I package and Directive (EU) 2026/470); the EU Forced Labour Regulation (Regulation (EU) 2024/3015); and the German Supply Chain Due Diligence Act (LkSG) where applicable through buyer relationships.

We recognise that handcrafted and natural-fibre sectors carry specific risks, particularly where home-based piece-rate work is common. We address these risks proportionately to our scale as a Micro Enterprise.

5. INDIAN LEGAL COMPLIANCE

Our operations comply with the following Indian statutes, which we treat as a baseline floor, not a ceiling.

5.1 Wages and Employment

• Minimum Wages Act, 1948: We pay wages at or above the rates notified by the applicable state government, revised semi-annually. Central floor rates effective October 2024 are ₹783/day (unskilled), ₹868/day (semi-skilled), ₹956/day (skilled), and ₹1,035/day (highly skilled). We apply whichever of the central floor rate or Haryana state notification is higher for our Gurugram facility workers.

• Payment of Wages Act, 1936: Wages are paid on time, without unauthorised deductions, and directly to each named worker.

• Equal Remuneration Act, 1976: We pay equal remuneration to men and women for work of equal value.

• Code on Wages, 2019: We monitor the phased implementation of this consolidating code and will comply with its provisions as they are notified and brought into force.

5.2 Working Hours and Safety

We do not require workers to work more than 48 hours per week or 9 hours per day. Overtime is voluntary and compensated at twice the ordinary wage rate. Workers receive a mandatory rest period of at least 30 minutes after every five hours of continuous work.

5.3 Social Security

• Employees’ Provident Funds and Miscellaneous Provisions Act, 1952 (EPF Act): Applicable once we reach 20 or more employees.

• Employees’ State Insurance Act, 1948: Applicable at 10 or more employees.

• Maternity Benefit Act, 1961 (as amended 2017): Women employees are entitled to 26 weeks of paid maternity leave.

• Payment of Gratuity Act, 1972: Employees who complete five or more years of continuous service are entitled to gratuity upon separation, calculated at 15 days’ wages per completed year.

• Social Security Code, 2020: We monitor the phased implementation and will comply with its provisions as notified.

5.4 Child and Bonded Labour

• Child Labour (Prohibition and Regulation) Amendment Act, 2016: We do not employ anyone below 14 years of age. We do not employ anyone aged 14 to 18 in any hazardous occupation or process. Age verification records are maintained for all workers.

• Bonded Labour System (Abolition) Act, 1976: We do not hold any worker in bonded labour. No deposits, identity documents, or personal property are held as security for employment. All employment is voluntary; workers are free to leave with reasonable notice.

5.5 Workplace Safety and Harassment Prevention

Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (POSH Act): The POSH Act applies to all workplaces regardless of size. Workplaces with 10 or more employees must constitute an Internal Committee (IC). Where the workforce is below 10, the District-level Local Complaints Committee (LCC) serves as the redressal mechanism. We maintain a policy prohibiting sexual harassment and ensure awareness of the Act’s provisions among all workers. We will constitute an IC in compliance with Section 4 of the POSH Act once our employee count reaches the statutory threshold, or immediately if it already meets or exceeds 10.

Factories Act, 1948: If and when our Gurugram facility qualifies as a “factory” under the Act (10 or more workers with the aid of power, or 20 or more without), we will register accordingly and comply with the factory inspectorate requirements, including health, safety, and welfare provisions.

• Occupational Safety, Health and Working Conditions Code, 2020: We monitor the phased implementation and will comply with its provisions as notified.

5.6 GST and Export Compliance

We are registered under the Goods and Services Tax Act (GSTIN: 06AAMCB7066N1Z2, Regular, Gurugram Jurisdictional Office, issued 26 August 2025). Our exports are zero-rated under Section 16 of the IGST Act, 2017. We maintain a valid Letter of Undertaking (Form GST RFD-11), renewed at the start of each financial year, and reconcile GSTR-1 and GSTR-3B returns with shipping bills and export documentation. GST and export records are maintained for 72 months as required by law.

5.7 Data Protection

We handle personal data of workers, artisans, and buyers in accordance with the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. We monitor the implementation of the Digital Personal Data Protection Act, 2023 and will comply with its provisions as rules are notified.

6. SUPPLY CHAIN STRUCTURE AND RISK ASSESSMENT

Our supply chain operates across three layers.

6.1 Layer 1 — Raw Materials

Natural fibres (Raffia, Rattan, Water Hyacinth, Palm Leaf, Kauna Grass, Bamboo) are sourced from harvesting communities and agricultural cooperatives. Full-grain leather is sourced from tanneries.

Key risks: Harvesting community working conditions, use of migrant labour in raw material collection, and tannery chemical processing safety.

6.2 Layer 2 — Artisan Production

Weaving, basketry, and finishing is carried out at our Gurugram facility and by home-based artisans on a piece-rate basis.

Key risks: Home-based piece-rate work is our highest-risk supply chain element. Risks include: difficulty in verifying working hours, the potential for multiple household members (including children) to contribute to output, limited access to formal grievance mechanisms, and the possibility of sub-minimum effective hourly rates if piece rates are set too low relative to production time.

6.3 Layer 3 — Export and Finishing

Quality control, packaging, labelling, and export documentation are handled at our Gurugram facility under direct supervision, where working conditions are observable and governed by the legal framework in Section 5.

7. DUE DILIGENCE MEASURES

We maintain the following due diligence measures, proportionate to our scale as a Micro Enterprise:

7.1 Facility Workers

• Individual wage and payment records maintained for all facility workers.

• Age verification documents retained on file.

• Wages paid at or above the applicable minimum wage rate.

7.2 Home-Based Artisans

• Periodic visits to home-based artisan households to observe working conditions.

• Direct payment to named artisans; no intermediary deductions.

• Artisans are free to work for other buyers simultaneously; no exclusivity requirements.

7.3 Raw Material Suppliers

• Known-supplier sourcing: we work with verified suppliers with whom we maintain ongoing relationships.

• We avoid sourcing from unknown or unverified intermediaries.

7.4 Limitations

We have not yet conducted formal third-party social audits of our supply chain. We consider direct, relationship-based oversight appropriate at our current scale as a Micro Enterprise, and will reassess this as export volumes grow and as buyer due diligence requirements evolve under the CSDDD and Forced Labour Regulation.

We have not identified any confirmed instance of forced labour, child labour, or human trafficking in our operations or supply chain during the financial year covered by this statement.

8. EU REGULATORY AWARENESS

Although Baghpat House is not directly in scope of the following EU regulations, we recognise that their requirements will reach us through our European buyers’ supply chain due diligence obligations:

8.1 Corporate Sustainability Due Diligence Directive (CSDDD)

Directive 2024/1760 (as amended by the Omnibus I package, Directive (EU) 2026/470) requires large EU companies to conduct human rights and environmental due diligence across their value chains. The amended directive raises the scope threshold to companies with more than 5,000 employees and over €1.5 billion turnover. The first phase of compliance applies from 26 July 2028, with full application from 26 July 2029. As a supplier to European buyers, we expect to receive due diligence questionnaires and contractual requirements from in-scope companies.

8.2 EU Forced Labour Regulation

Regulation (EU) 2024/3015 prohibits products made with forced labour from being placed on the EU market or exported from the EU. This regulation applies to all economic operators regardless of size, covers all products including components, and becomes applicable on 14 December 2027. We maintain this statement and our due diligence measures in part to demonstrate compliance readiness under this regulation.

8.3 General Product Safety Regulation (GPSR)

Regulation (EU) 2023/988 requires that products placed on the EU market are safe. We ensure our products meet applicable safety standards and maintain records of our supply chain sufficient to identify the origin of materials and components.

9. POLICIES

We operate with the following commitments:

• No use of forced, bonded, or involuntary labour in any form.

• No child labour. No employment of anyone below 14 years of age. No employment of anyone aged 14 to 18 in hazardous occupations.

• Fair wages aligned with or exceeding applicable legal minimums.

• Safe working conditions across all production environments.

• Freedom of association respected. Workers are free to organise and bargain collectively.

• No discrimination in employment on the basis of gender, caste, religion, ethnicity, disability, or any other protected characteristic.

• No retention of identity documents or personal property as a condition of employment.

• All overtime is voluntary and compensated at the statutory premium rate.

We expect all suppliers and partners to adhere to these standards. As we scale, we intend to formalise these expectations in a written Supplier Code of Conduct.

10. TRAINING AND AWARENESS

Core team members involved in sourcing, production, and operations are aware of ethical sourcing expectations and the indicators of forced labour as defined by the ILO. As the organisation grows, we intend to introduce formal training programmes on modern slavery risk identification and prevention.

11. GRIEVANCE MECHANISM

Workers at our Gurugram facility may raise concerns directly with management. We recognise that home-based artisans have limited access to formal grievance mechanisms. Developing an accessible, confidential reporting channel for artisans is a priority for the next financial year.

12. PLANNED ACTIONS FOR FY 2026–27

1. Formalise and publish a Supplier Code of Conduct aligned with ILO Core Standards.

2. Introduce documented supplier onboarding process with written acknowledgement of labour standards.

3. Establish a confidential grievance channel accessible to home-based artisans.

4. Conduct at least two visits to artisan households per quarter, documented with findings.

5. Strengthen traceability records linking finished products to specific artisans and material sources.

6. Begin preparing documentation to respond to CSDDD-related buyer due diligence questionnaires.

7. Evaluate readiness for the EU Forced Labour Regulation (applicable December 2027).

8. Constitute POSH Act Internal Committee once the 10-employee threshold is met, or verify current employee count and constitute immediately if already at or above threshold.

9. Assess Factories Act, 1948 applicability for the Gurugram facility and register if required.

13. APPROVAL

This statement has been approved by the Board of Directors of Baghpat House Exports Private Limited on 31 March 2026 and will be reviewed and updated annually.

_______________________________

Reena Nain

Director (DIN 07201715)

Chairperson and Managing Director

Baghpat House Exports Private Limited

Date: 31 March 2026

_______________________________

Dhananjay Chaudhary

Chief Executive Officer

Baghpat House Exports Private Limited

Date: 31 March 2026

ANNEX: REGULATORY REFERENCE TABLE

Regulations referenced in this statement, with their applicability to Baghpat House.

Indian Legislation

• Companies Act, 2013 — Governs incorporation, directorship, compliance

• Factories Act, 1948 — Factory registration and safety (if threshold met)

• Minimum Wages Act, 1948 — Floor wages for facility and piece-rate workers

• Payment of Wages Act, 1936 — Timely, direct wage payment

• Equal Remuneration Act, 1976 — Gender pay equity

• Child Labour (Prohibition and Regulation) Amendment Act, 2016 — Absolute prohibition below age 14

• Bonded Labour System (Abolition) Act, 1976 — Prohibition of all forms of bonded labour

• POSH Act, 2013 — Prevention of sexual harassment; IC required at 10+ employees; LCC for smaller workplaces

• EPF Act, 1952 / ESI Act, 1948 / Maternity Benefit Act, 1961 / Payment of Gratuity Act, 1972 — Social security

• MSMED Act, 2006 — Micro Enterprise classification and protections

• GST Act / IGST Act, 2017 — Tax compliance and zero-rated export

• FEMA, 1999 — Export proceeds repatriation

• Consumer Protection Act, 2019 and E-Commerce Rules, 2020 — E-commerce seller obligations

• Information Technology Act, 2000 — Data protection (interim)

• Digital Personal Data Protection Act, 2023 — Data protection (when notified)

• Code on Wages, 2019 / Social Security Code, 2020 / OSH Code, 2020 — Labour code consolidation (when notified)

• Foreign Trade Policy 2023 — E-commerce export framework for MSMEs

EU and International Legislation

• UK Modern Slavery Act, 2015 (Section 54) — Voluntary statement; threshold £36M

• EU CSDDD, Directive 2024/1760 (as amended) — Supply chain due diligence; first phase July 2028; full application July 2029

• EU Forced Labour Regulation, Regulation (EU) 2024/3015 — Product ban; applicable December 2027; no size threshold

• EU General Product Safety Regulation, Regulation (EU) 2023/988 — Product safety for EU market

• German Supply Chain Due Diligence Act (LkSG) — May apply through German buyer relationships

• ILO Core Conventions (29, 87, 98, 100, 105, 111, 138, 182) — Foundational labour standards

• UN Guiding Principles on Business and Human Rights (2011) — Due diligence framework

• OECD Due Diligence Guidance for Responsible Business Conduct (2018) — Six-step due diligence process