Modern Slavery and Human Trafficking Policy

Modern slavery & human trafficking are taken very seriously at Adveco Ltd. / Adveco (AWP) Ltd. (Adveco / A.O. Smith Water Heaters). We remain fully compliant with the Modern Slavery Act 2015 across all of our departments, working our way towards a world without slavery and human trafficking.

Modern Slavery and Human Trafficking (MSHT) Policy Statement

This statement sets out the Adveco Ltd. / Adveco (AWP) Ltd. (Adveco / A.O. Smith Water Heaters) actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

The organisation is absolutely committed to preventing modern slavery and human trafficking (MSHT) in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure:

• Adveco Ltd. is an application design, supply and service organisation for the built environment
• The organisation currently operates one site within the United Kingdom, and two sites in Europe
• Staff Profile – Adveco has no gender bias and employs full time and temporary contracted personnel

Supply Chain Adherence to our Values:

• Our Supply Chain includes a range of manufacturing organisations and engineering specialists. We engage with them to provide and assist the Company with labour and materials. We accept that there may be a risk to Adveco as we rely upon the practices of our supply chain to support our Business. However, we have a Zero tolerance to modern slavery and human trafficking and we expect all those in our supply chain and contractors to comply with our values.

The responsibility for enacting this Policy and ensuring compliance rests with the Board/Directors. They and the Senior Management are responsible for ensuring due diligence is carried out in relation to any issues raised around MSHT. It is the responsibility of all employees to understand the principles and apply its concepts in practice.

Adveco has an in-house policy which describe and lay out the minimum requirements for all our Staff, Supply Chain and any third parties.

Adveco is committed to conducting its business in accordance with applicable laws and to the highest ethical standards.

Adveco operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.

Employee code of conduct:

Adveco’s code of conduct makes clear to employees the actions and behaviour expected of them when representing the organisation.

The organisation strives to maintain the highest standards of employee conduct and ethical behaviour and also when managing its supply chain.

Supplier/Procurement code of conduct:

Adveco is committed to ensuring that its suppliers adhere to the highest standards of ethics.

Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.

Adveco will work with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.

Recruitment/Agency workers policy:

The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

It is also a condition of working for Adveco that all Sub Contractors and Supply chain Partners that salaries are paid at or above the minimum wage.

Corporate Social Responsibility Policy Statement:

Adveco recognises that our business activities have direct and indirect impacts on the communities and environment in which we operate. As a responsible employer we are committed to the principles of fair trade, respect for human rights and environmental protection.

Adveco is committed to valuing diversity, providing equal opportunity in employment, ensuring that the work environment is free of harassment and ensuring that all employees are treated with dignity and respect. Where any employee or contractor/third party supplier disregard these values, action may include disciplinary action or termination of contract.

Adveco supports the right of employees to raise any legitimate concerns about specified matters and these might include MSHT matters.

Adveco undertakes due diligence over its operations and when considering taking on new suppliers and reviewing existing suppliers.

The organisation’s due diligence and reviews include:

• conducting supplier audits or assessments
• taking steps to improve substandard suppliers’ practices
• invoking sanctions against suppliers that fail to improve their performance in or seriously violate our supplier code of conduct, including the termination of the business relationship
• Reviewing its existing supply chains on a regular basis
• Ensuring that all personnel engaged by Adveco or through recruitment agencies are vetted to ensure they have the right to work in the UK or European offices
• Ensure that all staff are familiar with the MSHT statement and their responsibilities

This statement is made pursuant to section 54(1) of the Modern Slavery and Human Trafficking Act 2015 and constitutes our company’s slavery and human trafficking statement for the current financial year.