NextGEN360 Ltd (part of the Wilson George Group)
Financial Year Ending 31 December 2025
1. Introduction
This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and sets out the steps taken by NextGEN360 Ltd, as part of the Wilson George Group, to prevent modern slavery and human trafficking in our business operations and supply chains.
While NextGEN360 Ltd operates below the statutory turnover threshold individually, the Wilson George Group approaches the threshold and adopts a group-wide commitment to responsible and ethical trading practices.
2. Our Business and Supply Chains
NextGEN360 Ltd is a UK-based business operating within the vaping and nicotine products sector, including the import, distribution, and sale of e-liquids, nicotine pouches, and related products.
Our supply chains include:
- Direct import of finished goods from international manufacturers
- UK-based manufacturers and logistics providers
- Third-party service providers supporting ecommerce and operations
We recognise that direct importing increases potential exposure to supply chain risks, particularly in manufacturing environments outside the UK.
3. Our Policies
We are committed to ensuring there is no modern slavery or human trafficking in our business or supply chains. Our approach is supported by the following principles:
- Compliance with UK employment law, including National Minimum Wage, National Living Wage, and Working Time Regulations
- Right-to-work verification for all employees
- Zero tolerance approach to forced labour, servitude, and human trafficking
- Expectation that all suppliers operate in accordance with applicable labour laws and ethical standards
We are working towards formalising this commitment through a documented Anti-Slavery and Human Trafficking Policy.
4. Due Diligence Processes
To identify and mitigate risks in our supply chains, we undertake proportionate due diligence, including:
- Supplier onboarding checks, including business legitimacy and trading history
- Maintaining records of supplier relationships and contracts
- Preference for working with established manufacturers and partners with a track record of compliance
- Ongoing commercial review of supplier performance
Where appropriate, we seek assurances from suppliers that they comply with applicable labour laws and standards.
5. Risk Assessment and Management
We recognise that the highest risk areas for modern slavery may arise within:
- Overseas manufacturing, particularly in higher-risk jurisdictions
- Lower-tier supply chains where visibility is limited
To manage these risks, we:
- Limit sourcing to known and vetted suppliers
- Avoid informal or unverified supply chains
- Maintain oversight of procurement decisions at a senior level
We will continue to review our risk exposure as the business grows.
6. Effectiveness and Monitoring
We assess the effectiveness of our approach through:
- Ongoing review of supplier relationships
- Internal oversight of recruitment and employment practices
- Monitoring for any indicators of unethical labour practices
At present, no instances of modern slavery have been identified within our operations or direct supply chains.
As part of continuous improvement, we aim to develop more formal key performance indicators over time.
7. Training and Awareness
Given the size and structure of the business, formal training programmes are currently limited. However:
- Key personnel involved in procurement and operations are aware of modern slavery risks
- Management maintains responsibility for identifying and addressing potential concerns
We will consider implementing more structured awareness training as the business scales.
8. Approval
This statement has been approved by the Directors of NextGEN360 Ltd and reflects our commitment to ethical business practices and continuous improvement in addressing modern slavery risks.
Signed: Ben Wilson
Name: Ben Wilson
Position: CEO
Date: 27 April 2026
