Modern Slavery Statement

Introduction from ADEY Group CEO

As ADEY continues to grow, innovate and enter into new markets we need to be alive to, and vigilant of, the risk that slave or child labour may be used somewhere in our supply chain, even indirectly.

The use of slave, or child labour, in any form is abhorrent and ADEY will play its part to ensure that we, and our supply chain, are not involved with these practices.

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that the ADEY Group has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain for the financial year ending 31st December 2020.

The ADEY Group comprises ADEY Innovation Limited,ADEYCommercial Limited, ADEY Holdings (2008) Limited, Alpha Scientific Limited, ADEY Innovation LLC, ADEY Innovation SAS and ADEY Innovation (Shanghai) Water Treatment Technology Co., Ltd

The ADEY Group employs over 271 people and has a combined turnover in excess of £50,800,000.

Where we refer to ADEY in this statement, we are referring to the ADEY Group as a whole and, where necessary, the relevant individual member of the ADEY Group. The structure of the ADEY Group means that the policies and practices described in this statement apply to all members of the ADEY Group without the need for additional management or administration to ensure compliance.

The ADEY Group is part of the Genuit Group Plc group of companies. Genuit Group Plc has its own statement regarding modern slavery which is separate from this statement.

What is Modern Slavery?

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. ADEY has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain. We undertake all practical steps to ensure that our standards are being implemented throughout the business of our suppliers and that local legislation and regulations are complied with.

Our Business

ADEY is the UK industry leading name in magnetic filtration, delivering best practice maintenance and protection products and services for domestic and commercial heating systems throughout the United Kingdom, Europe, North America and Asia.

Our Supply Chain

Our supply chain involves us purchasing goods, services and raw materials from suppliers all over the world. Whilst ADEY does attempt to source its supplies from as locally as possible, to reduce the environmental impact of its business, certain goods and raw materials, including rare-earth metals, can only be sourced from suppliers internationally, often from China.The policies and procedures ADEY has in place reflect the international nature of our supply chain and in particular, the higher risk of modern slavery and child labour associated with the mining of rare-earth metals.

Our Policies

At ADEY, we encourage openness and provide support to anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring that no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is, or may be, taking place in any part of our own business or in the businesses of any of our supply chains.

To support this, and to ensure that we are conducting business in an ethical and transparent manner, we have prepared and make use of a number of policies and practices. These include:

1. Recruitment policy: We operate a robust recruitment policy, including conducting all appropriate and required eligibility to work checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.

2. Equal Opportunities and Diversity Policy: This policy explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act. Our employees are collectively and personally responsible for the communication, understanding and practical application of this policy. The policy explains how ADEY expects employees to behave towards one another, and anyone they come into contact with and also allows employees to report any concerns they may have in a confidential and protected manner. This policy is made available to all new employees, and to our supply chain and to any other interested parties upon request.

3. Training: All relevant employees are required to undertake training in respect of how to identify the warning signs of slavery and exploitation. This includes the training of our procurement team to enable them to ensure that suppliers are conducting their business in a way in which complies with the standards that we set.

4. Responsible Trading: We are committed to maintaining high standards amongst our suppliers. This includes them adhering to our Supplier Charter. We oppose the exploitation of workers and we will not tolerate forced labour, or labour which involves physical, verbal or psychological harassment, or intimidation of any kind. We will not accept human trafficking or the exploitation of children and young people in our business and undertake all reasonable and practical steps to ensure that these standards are maintained, including having contracts in place with suppliers that include suitable provisions that oblige our suppliers to ensure they are complying with our policies with regard to modern slavery and human trafficking.

5. Supplier Visits: We endeavour to conduct site visits for all suppliers at least once a year, no matter where they are located, so that we can see, in person, how they conduct their business and how they produce and supply the products we are buying from them. During these visits we undertake a thorough review of the supplier’s practices, including assessing working conditions for their staff, to ensure they are complying with their obligations under ADEY’s Supplier Charter.

Signed:

Matthew Webber

ADEY Group CEO

10th May 2022

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