UK Modern Slavery Act 2015 Statement

RoC Skincare

For Fiscal Year Ended 31 December 2025

At RoC Opco LLC (“RoC”), we are committed to conducting business in a legal, ethical, and responsible manner and recognize the importance of safe working conditions around the world.

This UK Modern Slavery Act Statement by RoC, on behalf of the RoC group of companies, including its UK operating entity RoC Skincare (UK) Limited (this being a group statement made on behalf of RoC Opco LLC and its group companies, which together meet the turnover threshold under the Act), is made in accordance with section 54(1) of the UK Modern Slavery Act 2015 and outlines the actions undertaken in the fiscal year listed above to identify and minimize risks relating to modern slavery in our business and enterprise. This statement covers our financial year ended 31 December 2025. Because RoC substantially built out its modern slavery and responsible-sourcing program in the months following that year end, this statement also describes material steps taken since the reporting period, which we identify as such.

In this UK Modern Slavery Act statement, reference to “we” and “us” generally refer to the entire RoC group of companies unless expressly provided otherwise.

This Statement is organized under the six areas identified in section 54(5) of the UK Modern Slavery Act 2015, consistent with the Home Office’s Transparency in Supply Chains statutory guidance (March 2025).

1. OUR ORGANIZATION, BUSINESS AND SUPPLY CHAINS

A. Corporate Overview

• RoC is a skincare company founded in Paris in 1957, guided by the principle of being Clinically Proven and Ethically Driven. What began as a local Parisian brand has grown into a globally recognized name, and throughout that journey we have been guided by the belief that true success can only be achieved when we stay true to our values. Quality and attention to detail remain our competitive advantage in everything we create.

• Our business is built on a foundation of shared values—consumer obsession, disciplined execution, inclusion, humility, and integrity—and on the principle that doing the right thing is non-negotiable. These values guide how we treat our colleagues and how we expect our business partners and suppliers to operate.

B. Our Supply Chain

• We are committed to ensuring safety and transparency within our supply chain, and at RoC, doing the right thing is non-negotiable. Throughout our supply chain, we expect rigorous standards to ensure that our products are made with ethically sourced materials, are produced in a safe and sound manner, and are packaged and delivered with quality and care. We prioritize suppliers and third parties who conduct their business with transparency and integrity, respect fundamental human rights, provide safe and healthy working conditions, and are committed to the highest standards of ethical conduct and environmental practice.

• Our products are manufactured by third-party suppliers located across the United States and Europe. We are committed to partnering with third parties — including outsourced production, manufacturing, testing labs and warehouse sites — who prioritize the health and safety of their staff and regulatory compliance, and we engage suppliers only in accordance with our internal procedures.

• Our supply chain is multi-tiered. To ensure the integrity of our supply chain, we expect our supply chain partners to adhere to the standards we have set, and we adopt and implement procedures to monitor their continued compliance with applicable RoC policies and legal requirements, holding subcontractors to the same standards established by our Supplier Code of Conduct.

2. OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

A. Our Commitment to Human Rights

• RoC is committed to conducting its business responsibly and to respecting the rights of the people who work across our operations and supply chain. We provide a safe and healthy workplace for our colleagues and comply with applicable health and safety laws, regulations and international requirements, consistent with our Health, Safety and Product Quality Policy.

• We support human and workplace rights as articulated in the United Nations’ Universal Declaration of Human Rights which recognizes that “all human beings are born free and equal in dignity and rights”. We take a proactive approach to respecting fundamental human rights. We embed this commitment throughout our operations and supply chain, guided by our Human Rights and Modern Slavery Policy. This includes considering the potential impacts of our operations, and those of our supply chain partners, on work partners and on the local communities where we and our partners operate.

• As stated in our company’s policies, we expressly prohibit modern slavery of any kind in our operations and supply chain. We prohibit all forms of forced labor. This includes bonded, indentured and involuntary labor, as well as human trafficking and child labor. This prohibition applies both to our own operations and to any party that supplies goods or services to us. Consistent with our values, we prioritize working with suppliers and business partners that demonstrate a commitment to respecting fundamental human rights, providing safe and healthy working conditions, and advancing responsible business practices. We understand forced labor by reference to International Labour Organization Convention No. 29, namely all work or service exacted from any person under the menace of a penalty and for which that person has not offered themselves voluntarily.

B. International Standards We Follow

• Our policies in this area are guided by international standards including the United Nations Guiding Principles on Business and Human Rights, the UN Declaration of Human Rights, the fundamental rights set out in the International Labor Organization’s Declaration on the Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises.

C. Compliance with the Law and RoC’s Policies

• We require our suppliers to comply with applicable local and international laws and to adhere to the standards laid out in our Supplier Code of Conduct, our Human Rights and Modern Slavery Policy, and our Health, Safety and Product Quality Policy, as well as any other RoC policies applicable to them.

• RoC’s Supplier Code of Conduct (“Supplier Code”) sets out the baseline standards all suppliers, vendors, distributors, subcontractors and other third parties must meet, and is designed to protect the rights of workers in our supply chain and ensure compliance with applicable laws.

• Consistent with the United Nations Guiding Principles on Business and Human Rights and core ILO conventions, the Supplier Code requires suppliers to conduct business with integrity and in compliance with anti-corruption, anti-bribery, and anti-money laundering laws, and prohibits modern slavery in all forms, including forced, bonded, or involuntary labor, human trafficking, and child labor. The Supplier Code further requires respect for freedom of association and collective bargaining, fair treatment free from discrimination, harassment or abuse, and payment of at least the legal minimum wage with required benefits. The Supplier Code also addresses ethical sourcing, including conflict minerals and the rights of indigenous peoples and local communities, health and safety, product quality and environmental responsibility.

• The supply chain requirements are reinforced internally by RoC’s own Anti-Bribery and Corruption Policy and Economic Sanctions and Anti-Money Laundering Policy, which apply to our colleagues, and inform our supplier due diligence and screening. We recognize that corruption, bribery and sanctions evasion can be used to conceal or facilitate modern slavery and other human rights abuses within a supply chain, and our anti-corruption and sanctions compliance program is accordingly a component of our broader efforts to identify and address modern slavery risk.

• All new suppliers retained in the United States must review the Supplier Code and confirm their commitment to its standards. Suppliers are expected to report known or suspected violations without fear of retaliation, maintain appropriate internal controls and records, cooperate with RoC’s due diligence, audits and investigations, and implement corrective actions where issues arise. Failure to meet these standards, or to cooperate, may result in suspension or termination of the business relationship. Suppliers must not require workers to pay recruitment fees or to lodge deposits or identity documents as a condition of employment, and workers must be free to leave their employment after reasonable notice.

D. Our People

• RoC has no tolerance for modern slavery, forced labor, or human trafficking anywhere within its supply chain. We are equally committed to fostering a safe, respectful, and supportive environment for our employees, grounded in fair treatment, dignity, and the protection of fundamental human rights.

• This commitment is set out in our Code of Business Conduct, our Environmental, Social and Governance Policy, our Human Rights and Modern Slavery Policy, and our Health, Safety and Product Quality Policy.

• Our Code of Business Conduct is the foundation of our approach to ethical conduct. Our Company’s Code of Business Conduct sets our expectations for our colleagues, partners and suppliers on a variety of ethical issues. Adherence to the Code is a condition of working at RoC, and our colleagues complete training on the Code and related policies annually.

Diversity, Equity, Inclusion & Fair Wages

• RoC protects its employees’ rights primarily through commitments to a diverse, equitable, and non-discriminatory workplace, free from harassment or bullying. This includes equal opportunity in recruitment, promotion, and professional development based on merit. Alongside this, RoC commits to fair wages – equal pay for equal work regardless of protected characteristics, and timely payment in full without unauthorized deductions or delays.

Good Health, Freedom of Association & Collective Bargaining

• RoC also commits to employee health, safety, and well-being, covering physical and mental health support, manageable workloads to reduce stress and burnout, fair working hours and rest periods, career development opportunities, and a stigma-free environment for discussing mental health, backed by the company’s Health, Safety and Product Quality Policy. Employees’ collective rights are further protected through RoC’s commitment to freedom of association and collective bargaining, in line with local laws and ILO conventions, including the right to form or join unions without fear of retaliation or intimidation.

Grievance Mechanisms and Whistleblowing

• We have established dedicated speak-up channels, including an anonymous and confidential online reporting tool (RoC’s “Whistlelink”) available seven days a week, to ensure that colleagues and others have a safe and confidential channel to voice their concerns, including on modern slavery or labor issues. Concerns may also be raised directly with our General Counsel. We take all raised concerns seriously and are committed to addressing them promptly and fairly. RoC prohibits retaliation of any kind against anyone who raises a concern in good faith.

3. OUR DUE DILIGENCE PROCESSES

A. Responsible Sourcing, Supplier Screening and Monitoring

RoC's approach to responsible sourcing is implemented through the policies and programs described in this statement, including our Supplier Code, and our supplier screening and monitoring.

Screening Before Onboarding

• RoC operates a risk-based third-party due diligence program through which suppliers, vendors and other third parties are screened before they are onboarded, contracted or paid, and monitored over the course of our engagement with them. Prospective third parties complete a risk questionnaire, and their responses are screened against our risk criteria, including sanctions, anti-corruption, human rights and modern slavery risk, using automated screening tools together with trained human review. In the first quarter of 2026, since the reporting period, RoC screened 427 existing active vendors on an enterprise-wide basis against trade sanctions, anti-corruption, modern slavery, forced labor and reputational-risk criteria. Since the U.S. onboarding portal went live in May 2026, an additional 36 new vendors have been approved, of which 15 were cleared subject to specific contractual provisions or enhanced due diligence.

• Based on that review, a third party is cleared, escalated for enhanced due diligence, or rejected, and no third party is onboarded, contracted or paid without clearance. Where issues are identified, we work with the third party to implement corrective actions.

Ongoing Monitoring

• Approved vendors must sign an agreement with RoC that includes audit and monitoring rights, enabling RoC to review the third party if indicators of potential human rights violations emerge.

• In addition, RoC regularly screens approved third parties against watchlists to identify recent adverse media or other red flags, including any indicators of potential human rights violations. Watchlist and adverse-media re-screening of approved third parties is operational, and we are extending periodic re-screening of key vendors as the program matures.

• The program currently operates for our U.S. vendor engagements and is being extended to RoC’s other markets during 2026. Contractual audit and monitoring rights are established across our manufacturing and supply partners through our Supplier Code of Conduct and quality agreements, and a formalized supplier audit program, including labor and human-rights criteria, is a priority for the coming year. We report this transparently: we do not yet operate a formalized modern-slavery audit program, and we regard establishing one as an area for improvement rather than a step already completed.

B. Oversight, Audits and Investigations

• Our Executive Leadership Team is responsible for promoting, monitoring and enforcing compliance with our Code of Business Conduct, and our supplier relationships are managed through the risk-based due diligence and screening processes described above. In addition to this operational oversight, RoC’s Board of Directors has appointed a Board member to oversee ESG matters, including human rights and modern slavery risk, in coordination with, and with the support of RoC’s Executive Leadership Team. ESG matters, including our progress in addressing modern slavery risk, are reported to and discussed with the Board of Directors at least annually, and with the Executive Leadership Team at least twice annually.

• Where suppliers operate in higher-risk regions, we exercise heightened diligence to help prevent modern slavery and other human rights violations. When risks are identified within our supply chain, we work with the relevant supplier to address them, including through corrective action plans with clearly defined timelines for improvement.

• At RoC’s request, suppliers must cooperate with audits, inspections and investigations to evaluate their business integrity and their compliance with applicable laws, our Supplier Code, and our manufacturing and quality requirements. Where appropriate, this may include onsite audits, together with quality control, testing and reporting relating to product safety and regulatory compliance.

• Where deficiencies or potential violations of our Supplier Code, our manufacturing or quality agreements, or applicable law are identified, we investigate and require the supplier to cooperate in good faith with corrective action plans and ongoing monitoring where necessary. A supplier’s refusal to cooperate with our audits, or its failure to implement corrective measures in a timely manner, may result in suspension or termination of the business relationship.

4. RISK ASSESSMENT AND MANAGEMENT

• We recognize that the risk of modern slavery is not evenly distributed across our business and supply chain. We consider the inherent risk of modern slavery and human trafficking to be higher in areas such as the sourcing of raw materials and ingredients, lower-tier manufacturing and processing, and the use of agency, temporary or migrant labor, particularly in higher-risk geographies.

• Our finished products are manufactured by third-party suppliers located primarily in the United States and Europe, while we recognize that certain raw materials and components may be sourced from a broader range of regions. We assess and prioritize these risks through our third-party due diligence and supplier screening, and we focus our heightened diligence, monitoring and screening activity on the suppliers and regions we assess to present the greatest risk.

5. ASSESSING OUR EFFECTIVENESS

• We monitor and verify compliance across our supply chain through the measures described in this statement, including adherence to our Supplier Code of Conduct and risk-based screening and due diligence of suppliers, together with the audit and monitoring rights described above (which, where exercised in future, may include, where appropriate, on-site audits), and corrective action, up to suspension or termination, where our standards are not met.

• We seek to assess the effectiveness of our efforts to prevent modern slavery on an ongoing basis. We do so by reference to indicators such as the proportion of our suppliers that have accepted and committed to our Supplier Code of Conduct, the completion of due diligence screening before new suppliers are onboarded, the outcomes of our supplier audits and any resulting corrective actions, and the completion of relevant compliance training by our colleagues. Since the reporting period, these indicators have included all 24 of our manufacturing and supply partners having accepted and committed to our Supplier Code of Conduct following its launch in March 2026, 427 existing vendors screened enterprise-wide in the first quarter, 36 new vendors screened and approved through our onboarding portal since May 2026 (15 of them subject to specific contractual provisions or enhanced due diligence), a 100% completion rate for our Code of Business Conduct certification, and no labor or human-rights concerns raised through our supplier-facing speak-up channels during the period.

• Consistent with the Home Office Transparency in Supply Chains guidance, we report these indicators transparently, including where they identify areas for improvement, and we note that a formalized supplier audit program remains under development.

• We also consider indicators relevant to our own workforce, such as employee demographic data and the promotion and retention rates of diverse talent, as part of our broader assessment of fair treatment and equal opportunity within RoC. We review these indicators over time and use what we learn to strengthen our policies, due diligence and training. Consistent with our broader ESG approach, we recognize that this is an ongoing effort, and we are committed to regularly reviewing and updating our Human Rights and Modern Slavery Policy and related policies to reflect our progress and emerging best practices. We also recognize the current limits of our supply-chain visibility, including in respect of lower-tier suppliers and certain raw material origins, and we are taking steps to improve this mapping over time.

6. TRAINING

• We provide compliance training to relevant colleagues through our online learning platform, including an annual certification of our Code of Business Conduct. We are expanding this program to address human rights, modern slavery and human trafficking risks, and are developing dedicated training in this area. In the most recent cycle, 100% of colleagues completed this certification.

This statement was approved by the Manager of RoC Opco LLC for our fiscal year ended 31 December 2025.

Richard P. Davies
General Counsel & Chief Administrative Officer, RoC Opco LLC