Human Rights and Ethical Sourcing Policy
Corporate Governance Standard: Human Rights and Ethical Sourcing Policy
Policy Reference: HR Compliance Framework (Standards HR 1.1 & HR 4.2)
Effective Date: May 2026 | Version: 2.0 (Public Disclosure & Procurement Addendum) | Review Date: May 2027
Governance Ownership: Highest Governing Body (Sole Director / Executive Leadership)
Public Location: www.atenailondon.com/pages/Human Rights and Ethical Sourcing Policy
Foundational Ethos & Commitments
At Atenai London, our core design philosophy—‘Wellbeing, Designed Through Scent’—extends far beyond individual sensory rituals to encompass the baseline rights, health, safety, and dignity of every individual touched by our business activities. We believe that modern luxury must be fundamentally mindful, transparent, and accountable.
In full alignment with B Corp certification criteria, our corporate mission demands that we respect human rights across our internal operations, external multi-tier supply chains, and local communities.
This document serves as our binding public commitment and operational framework under B Corp Standards HR 1 and HR 4. Through proactive executive oversight, salient risk mapping, and collaborative supplier engagement, Atenai London ensures that its luxury personal care and fragrance portfolio is built upon an unyielding foundation of social justice and human dignity.
1. Human Rights Commitment & International Framework Alignment [Standard HR 1.1]
1.1 Public Commitment & Scope
Atenai London maintains a formal, publicly accessible commitment to respecting all internationally recognized human rights. This policy applies to all aspects of our business operations, including direct corporate activities, contractors, manufacturing partners, raw material suppliers, packaging vendors, and fulfillment partners.
1.2 Alignment with International Frameworks
Our commitment is explicitly anchored in and guided by the following international governance instruments:
1. The Universal Declaration of Human Rights (UDHR): We uphold the fundamental freedom, equality, and dignity of all human beings without distinction of any kind.
2. The UN Guiding Principles on Business and Human Rights (UNGPs): We adhere to the three pillar framework: the state duty to protect human rights, the corporate responsibility to respect human rights, and the need for greater access to effective remedy for victims of business-related abuses.
3. The ILO Declaration on Fundamental Principles and Rights at Work: We uphold core International Labour Organization (ILO) conventions regarding freedom of association, the right to collective bargaining, the elimination of all forms of forced or compulsory labor, the effective abolition of child labor, and the elimination of discrimination in respect of employment and occupation.
1.3 Core Human Rights Pillars
· Absolute Dignity & Non-Discrimination: We guarantee a working environment completely free from discrimination based on race, gender, sexual orientation, age, religion, disability, or social origin. We maintain zero tolerance for workplace harassment, abuse, or systemic marginalization.
· Prohibition of Forced Labor & Modern Slavery: We strictly prohibit any form of forced, bonded, indentured, or involuntary labor, human trafficking, or restriction of worker movement across all supply chain tiers, in strict compliance with the UK Modern Slavery Act 2015.
· Protection of Child Labor: We enforce a strict zero-tolerance policy against child labor in accordance with ILO Conventions 138 and 182. Sourcing partners must maintain verified age-verification protocols.
· Fair Work, Living Wage & Safe Working Conditions: We ensure safe, healthy, and ergonomically sound working conditions, fair working hours, and transparent remuneration protocols aligned with or exceeding national living wage benchmarks.
· Freedom of Association & Collective Bargaining: We respect the legal rights of workers to form or join trade unions and engage in collective bargaining without fear of reprisal, discrimination, or intimidation.
· Universal Non-Retaliation & Grievance Access: Stakeholders across all tiers (including suppliers' workers and local communities) can voice concerns or lodge grievances via our public portal (https://atenailondon.com/pages/purpose-stakeholder-governance-psg) under standard PSG 3, protected by our strict Non-Retaliation and Whistleblower Policy.
2. Salient Human Rights Due Diligence & Supply Chain Procurement [Standard HR 4.2]
Atenai London recognizes that our supply chain footprint represents our most significant area of potential human rights impact. We actively reject passive supplier vetting, enforcing a quantitative, risk-based Human Rights Due Diligence (HRDD) process across all procurement decisions.
2.1 Material Procurement Prioritization Methodology
We identify and prioritize our material procurement decisions annually based on Annual Spend (£), Volume (Units/Tonnage), and Salient Human Rights Risks (evaluating Likelihood and Severity—specifically Scale, Scope, and Ease of Remediation).
For the applicable fiscal period, our Top 3 Material Procurement Decisions and their salient human rights assessments are:
Decision 1: Direct Formulation Sourcing & Bulk Botanical Extraction
· Materiality Focus: UK/European GMP Contract Laboratories & Tier 2 Botanical Harvesting Partners.
· Salient Issues Evaluated: Fair wages for agricultural harvesters, safe handling of natural active ingredients/aromatics, forced labor prevention in upstream raw botanical supply chains.
· Assessment Framework:
o Scale & Scope: Global agricultural supply chains for natural essential oils present elevated risks of working hour violations and seasonal informal labor.
o Ease of Remediation: High. Managed through certified supply chain partners maintaining Michael Edwards Fragrances of the World database compliance, cruelty-free, vegan, and fair-trade botanical sourcing declarations.
· Due Diligence Action: Annual supplier audit reviews, signed Responsible Supplier Codes, and full traceability declarations back to extraction origin.
Decision 2: Primary Packaging Component Manufacturing
· Materiality Focus: Specialist Overseas Moulding & Assembly Suppliers (30% rPET / PCR Plastic Component Manufacturing).
· Salient Issues Evaluated: Workplace health and safety (moulding machine safety, chemical fumes), fair working hours, overtime compensation, and worker living conditions in manufacturing facilities.
· Assessment Framework:
o Scale & Scope: Factory-floor labor intensity carries potential risks regarding mandatory overtime and occupational health.
o Ease of Remediation: Moderate. Requires direct factory engagement, third-party social compliance audits (SEDEX/SMETA, BSCI, or ISO 45001), and clear contractual remediation clauses.
· Due Diligence Action: Pre-contract risk screening, mandatory third-party audit disclosure, and binding adherence to Atenai London's maximum working hour standards.
Decision 3: Secondary Packaging, Storage & Localized Fulfillment Services
· Materiality Focus: Regional Packaging Converters & Third-Party Warehousing / Freight Logistics Partners.
· Salient Issues Evaluated: Warehouse physical safety, agency worker treatment, equal pay, and living wage compliance within UK & European distribution networks.
· Assessment Framework:
o Scale & Scope: High volume during seasonal peak sales periods increases reliance on temporary/agency staff.
o Ease of Remediation: High. Localized UK/EU legal frameworks allow for direct site visits, living wage verification, and immediate agency partner engagement.
· Due Diligence Action: Verification of Living Wage Foundation standards, review of agency worker contracts, and logistics facility safety audits.
2.2 Operational Due Diligence Controls & Corrective Action
1. Pre-Onboarding Screening: Prior to contract execution, all new vendors must complete the Atenai Supplier Human Rights & Environmental Screening Questionnaire. Any vendor presenting unmitigated high-risk findings regarding forced labor, child labor, or severe safety violations is barred from our supply chain.
2. Multi-Tier Traceability: Primary formulation and packaging partners must disclose key Tier 2 raw material and component suppliers to enable upstream risk mapping.
3. Mandatory Remediation Protocol: If an audit or grievance identifies an actual or potential human rights impact within a supplier's facility, Atenai London issues a Corrective Action Plan (CAP) requiring remediation within 30 days. Failure or refusal to execute corrective measures results in immediate contract suspension or termination.
3. Governance, Oversight & Annual Review
· Executive Accountability: The Highest Governing Body of Atenai London Limited (Founder & Sole Director, Nuno Silva) holds ultimate operational and legal accountability for the implementation, monitoring, and performance of this policy.
· Annual Review & Continuous Improvement: In compliance with B Corp criteria, this policy and its underlying Procurement Risk Registry are formally reviewed, updated, and re-approved annually every January (next scheduled review: January 2028).
· Public Transparency: This document is publicly available to all stakeholders, customers, and partners via our digital governance page.
Approved and Executed by the Highest Governing Body:
Nuno da Silva
Founder & Sole Director, Atenai London Limited
Date: October 18, 2026
