The Modern Slavery Act – Anti-Slavery and Human Trafficking Policy Statement 2022/23

In accordance with the Modern Slavery Act 2015, Interfloor Limited (“Interfloor” or “we”) is committed to a work environment that is free from human trafficking, forced labour and unlawful child labour (collectively “human trafficking and slavery”). We also strongly believe that we have a responsibility for promoting high standards in ethical and lawful employment practices.  We also impose the same high standards on our suppliers.

• Human Trafficking is the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.
• Forced Labour is where all work or service, not voluntarily performed, that is obtained from an individual under the threat of force or penalty.
• Harmful Child Labour consists of the employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral, or social development.

Human trafficking and slavery are crimes under UK and international law. These crimes exist in countries throughout the world. This policy statement defines Interfloor’s commitment to ensuring that human trafficking and slavery does not exist within its own business, but also provides how Interfloor will make efforts to eradicate the same from other businesses with whom it shall maintain a relationship (and especially from within its supply chain).

Organisation Structure and Supply Chains

Interfloor Limited, part of Victoria PLC, is Europe’s largest manufacturer and supplier of floorcovering underlays and accessories based at its two sites (Haslingden in Lancashire and Dumfries in Southwest Scotland).  To find out more about Interfloor visit www.interfloor.com

We have a global supply chain purchasing commodities, materials, packaging, utilities, services and goods for resale from across the world.

Policies in relation to slavery and human trafficking

We will not knowingly use unlawful child labour or forced labour in any of the products and/or services we provide, nor will we accept commodities, products and/or services from suppliers that employ or utilize child labour or forced labour.

Our recruitment processes are in line with UK employment laws, including “right to work” document checks, contracts of employment, and checks to ensure everyone employed is of legal working age. We offer market-related pay and rewards which are reviewed annually.  We employ directly and do not use labour providers.

We have an ethical trading policy which outlines our commitments to ensure both we and our suppliers meet as a minimum the ETI base code and we are also a Foundation Member of the Ethical Trading Initiative.

We have a supplier charter that commits our suppliers to agree that they:

• Will not use forced or compulsory labour, i.e., any work or service that a worker performs involuntarily, under threat of penalty;
  • Will ensure that the overall terms of employment are voluntary;
  • Will comply with the minimum age requirements prescribed by applicable laws
  • Will compensate its workers with wages and benefits that meet or exceed the legally required minimum and will comply with overtime pay requirements;
  • Will abide by applicable law concerning the maximum hours of daily labour;
  • Will not engage in any practice of slavery, servitude, forced labour, compulsory labour and/or human trafficking outside the UK which would constitute an offence if that conduct took place within the UK; and
  • Will ensure that any sub-contractors or suppliers from whom they source goods and/or services for incorporation in those supplied to Interfloor, also adhere to these requirements.

Due diligence processes

Firstly, we are pleased to report there were no reported or identified instances of modern slavery and human trafficking in the last financial year 2022/23.

Within the last financial year 2022/23, we have undertaken a number of actions in pursuit of our aims:

• A full audit of our own business was undertaken against ETI base code
• A number of workshops and training events organised by one of our major retail customers on modern slavery
• A restructure within the Procurement Team to focus on ethical trade approach
• Further development of our supplier charter and Supplier Relationship Management framework putting ethical trading and modern slavery at its foundation
• Continued work with ETI moving towards full membership
• Maintenance of our SEDEX membership and online self-assessment questionnaires

Risk assessment and Management

We have appointed our Human Resources Director as our senior compliance officer (Anti- Slavery and Human Trafficking Officer) and will take appropriate steps to ensure not only our own compliance but also that these requirements are followed by our suppliers, subcontractors and/or business partners (collectively by its “Suppliers”) worldwide.

He reports annually to our Board of Directors in relation to the procedures we have in place, audit results and supply chain experience.

Any breach of our policy is reported to the Board without delay and investigated thoroughly with clear and transparent action taken.

Key performance indicators to measure effectiveness of steps being taken

Whilst the pandemic over the past few years seriously limited our ability to visit and audit our supply chain, we are finally starting to get out there and there our key measures to be developed over the next 3 years are:

Our own business

• 100% compliance with all aspects of ETI base code

Strategic suppliers (high spend/high dependency)

• 100% signed up to our Supplier Charter and to have completed a SMETA audit

Key suppliers (lower spend/high dependency)

• 66% signed up to our Supplier Charter and to have completed a SMETA audit

Operational suppliers (high spend/lower dependency)

• 33% signed up to our Supplier Charter and to have completed a SMETA audit

Training on modern slavery and trafficking

At Interfloor we recognise the risk of modern slavery is forever present and we therefore regularly focus on the ability of key personnel to spot the signs of risk on both our own business and within our supply chain.  We ensure that training is regularly available.  In terms of supply chain our buyers are all CIPS members who undertake annual training and recertification in ethical trading including modern slavery.

Authorised by John Cooper – CEO

Dated 31 March 2023