Modern Slavery

This statement applies largely to Eggfree Cake Box Limited (ECB), which was the only trading arm of Cake Box Holdings PLC (CBH) until the acquisition of Ambala Foods Ltd on 21 March 2025. The information included in this statement refers to the 52-week period ended 30 March 2025. 

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.  

Within CBH, ECB is a franchise retailer and manufacturer of egg-free cakes with a growing store base across the UK and France. The Group specialises in making high-quality, individually crafted and personalised fresh cream cakes, and confectionery for purchase on demand or orders placed in advance, in-store or online. 

CBH head office is based in Enfield, with two other bakery and distribution sites based in Coventry and Bradford. CBH has grown predominantly through franchise expansion and today does not directly own or operate any Cake Box stores. As of 30 March 2025, the franchise estate includes 109 franchisees, a total of 251 shops and 24 kiosks across the UK and one shop in France. 

For ECB, all procurement is done via head office (other than fresh fruit, which is sourced locally). This also includes the ingredients, equipment, and materials used by franchisees. This means all products (other than fresh fruit) sold from every Cake Box store have been procured centrally. Goods and services are sourced from just over 150 suppliers, which are predominantly based in the UK and the European Union. ECB also sources products such as balloons, candles, packaging and goods for resale from China and Turkey. We have visibility over the primary manufacturers of the goods we buy from, and the country of origin of the key raw materials.  

Ambala Foods Ltd is a specialist supplier of Asian sweets and savoury gifts, and snacks largely for an audience of Indian subcontinent origins. It currently operates 19 company-owned stores and three franchisee-owned stores throughout the UK, and in addition, a franchise roll-out in a similar fashion to ECB is imminent. 

CBH is in the process of assessing the risks linked to Ambala Foods Ltd.’s operations and supply chain. It is the vision of the CBH executive to align all policies and procedures of Ambala Foods Limited with those already established in ECB. This process will be ongoing for the rest of the financial year 2025-2026. 

ECB has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all business operations and relationships. They aim to implement and enforce effective systems and controls to reduce the risk of modern slavery and human rights abuse within the business, franchise estate, and supply chain. 

ECB colleagues are encouraged to raise concerns if they become aware of, or suspect any conduct violating any law, rule, regulation, or CBH’s policies. CBH's Whistleblowing Policy describes the procedure and different channels through which CBH employees can report any actual or suspected misconduct, ensuring that colleagues reporting their concerns remain anonymous and are protected from retaliation. The policy is reviewed annually, and any changes are communicated to employees. No case of suspected modern slavery has been reported using the whistleblowing line or any other channel.  

All franchisees must register with an outsourced HR provider that provides all people-related policies to which franchisees must adhere, which are on par with ECB’s standards. The outsourced HR provider also provides franchisees with expert support and advice, notably on employee contracts and documentation. This ensures that all individual franchise shops follow the same robust employment policies and standards. 

CBH has high ethical standards for the individuals and organisations they do business with. CBH has a Supplier Code of Conduct outlining what is expected from all contractors and suppliers. The Supplier Code is based on the Ethical Trading Initiative (ETI) base code, an internationally recognised code of labour practice founded on the conventions of the International Labour Organisation (ILO). The key components of the Supplier Code relating to the Modern Slavery Act include child labour, forced labour, discrimination, working hours and wages, freedom of association, and health and safety. All suppliers and franchisees are required to acknowledge the Supplier Code, which is systematically included in all purchase orders issued. In addition, CBH adopted in 2024 a Sustainability Policy, which outlines the company’s supplier risk assessment approach. Both the Supplier Code and the Sustainability Policy are reviewed annually.

The risk of modern slavery and human trafficking in the business sits predominantly in the franchise estate and supply chain. CBH’s ESG Committee oversees the management of modern slavery risks, including the implementation of relevant measures by the Technical Team and the monitoring of their effectiveness.  

Own operations 

Even though the risk of modern slavery in CBH’s own operations is low, the company has systems in place to increase the likelihood of detecting any potential cases of modern slavery. ECB uses a payment system which flags any bank account shared by more than one employee. 

Franchisees

ECB franchisees operate independently, with support from ECB. All new franchisees receive a mandatory four-day training course that covers human resources management, health and safety, and labour rights. All franchisees also receive annual refresher training on modern slavery.  

ECB divides the franchisee estate into five regions; each region has an Audit Compliance Officer, supported by a Sales Support Manager who audit all franchisees at least once a quarter. During the audits, Compliance Officers verify payslips to ensure that all franchise employees are paid at least the minimum wage. ECB provide recommended rates of pay to all franchisees that exceed the minimum wage. In addition, Audit Compliance Officers and Sales Support Managers are trained on modern slavery and are expected to flag to CBH any signs of potential cases they detect on the ground. 

Suppliers 

CBH works closely with suppliers to ensure high ethical standards across the supply chain. Every purchase order issued refers to the Supplier's Code of Conduct. CBH expects its business partners to communicate CBH standards with lower-tier suppliers. The company mitigate the risk of human and labour rights abuse by building long-lasting relationships with suppliers and works with sustainability consultants to analyse ethical risks in the value chain and identify high-risk suppliers.   

CBH requires all raw materials, food products and food packaging suppliers to complete self-assessment questionnaires, allowing the company to better understand their business and prioritise those suppliers that require the most attention. In addition, CBH requires all high-risk suppliers to submit an independent audit undertaken by third-party experts (e.g. SEDEX, BSCI) every two years.  

As of 30 March 2025, 100% of high-risk suppliers complied with this requirement.  

CBH has not identified any incidents of modern slavery in its operations, franchise estate, or supply chain.  

ECB recognises the importance of training to ensure employees can identify the signs of modern slavery and act on them appropriately. The Learning & Development Manager delivers training on modern slavery and human trafficking to franchisees at onboarding stage and thereafter on an annual basis, as well as to CBH’s Management Team, Sales Support Managers and Audit Compliance Officers, who conduct quarterly shop audits, every twelve months. The Board of Directors also receive an annual refresher training on modern slavery from external specialists. All training is adapted to the learners’ roles and focuses on information which they would need to have to detect potential modern slavery cases.  

In addition, SEDEX, BSCI audits cover assessment of training of suppliers on modern slavery.