MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR THE FINANCIAL YEAR 2020

As a SME trading below the threshold we are not required to make a formal statement. However we do recognise that many of our clients will be seeking reassurance from us about our compliance with the requirements of the Modern Slavery Act

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We are committed to improving our practices to combat slavery and human trafficking.

ORGANISATION

This statement applies to The DisceteHeat Company Limited. The information included in the statement refers to the financial year 2020.

ORGANISATIONAL STRUCTURE

We are a privately owned business based at 1 Victoria Works Industrial Estate, Coal Pit Lane, Atherton, Manchester. M46 0FY. The organisation is controlled by a Board of Directors.

We sell skirting heating and ancillary products in the UK and other parts of Europe. The sale of these goods is via the website, social media and through marketing materials.

Demand for the product is throughout the year and is not seasonal. The labour supplied to The DisceteHeat Company Limited in pursuance of its operation is carried out throughout the United Kingdom.

DEFINITIONS

The DisceteHeat Company Limited considers that modern slavery encompasses:

• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
• Being dehumanised, treated as a commodity or being bought or sold as property;
• Being physically constrained or to have restriction placed on freedom of movement.

COMMITMENT

The DisceteHeat Company Limited acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The DisceteHeat Company Limited understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The DisceteHeat Company Limited does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to The DisceteHeat Company Limited in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The DisceteHeat Company Limited strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom and Europe.

SUPPLY CHAINS

In order to fulfil its activities, The DisceteHeat Company Limited’s main supply chains include those related to various manufacturing companies who supply the skirting heating panes and the various ancilarys that go with it. We have conducted a risk assessment as part of our supplier approval process.

POTENTIAL EXPOSURE

In general, The DisceteHeat Company Limited considers its exposure to slavery/human trafficking to be relatively low, nevertheless it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

STEPS

The DisceteHeat Company Limited carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The DisceteHeat Company Limited has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery. In accordance with section 54(4) of the Modern Slavery Act 2015, The DisceteHeat Company Limited has taken the following steps to ensure that modern slavery is not taking place:

We have in place policies and systems across our business; our trading partners; and our supply chains to:- • • • • Protect whistleblowers; and • Investigate reports of Modern Slavery.

• Identify inappropriate employment practices;
• Identify, assess and monitor other potential risk areas;
• Mitigate the risk of slavery and human trafficking occurring;
• Protect whistleblowers and Investigate reports of Modern Slavery.

SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we operate in line with principles of responsible sourcing, including paying employees at the prevailing minimum wage applicable within their relevant country of operations. We have in place a Supplier Code of Conduct which outlines our expectations. The relevant account managers will monitor and enforce compliance of the Supplier Code of Conduct.

TRAINING

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, in our supply chains and in our business partners, we provide relevant training to our colleagues. Under our Supplier Code of Conduct we also require our business partners to provide regular and relevant training to their staff and suppliers and providers.

SLAVERY COMPLIANCE OFFICER

The DisceteHeat Company Limited has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to The DisceteHeat Company Limited obligations in this regard. This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Russ Hamer - Operations Director

03/03/2021