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Modern Slavery and Human Trafficking Statement

Financial Year 2025

This Modern Slavery and Human Trafficking Statement relates to the actions and activities of Ventmann UK Ltd. during the financial year ending 2025.

Ventmann UK Ltd. is committed to preventing slavery and human trafficking in all our business operations and supply chains. We take our responsibilities seriously and strive to ensure that no form of modern slavery exists within any part of our organisation. All staff have a duty to remain alert to potential risks, report any concerns, and cooperate fully with management in addressing them.

Organisational Structure and Supply Chains

This statement covers the business activities of Ventmann UK Ltd., which include the wholesale of architectural diffusers and other intermediate products within the HVAC and construction industries.

The Company currently operates exclusively within the United Kingdom and works with selected suppliers across Europe and other regions for sourcing high-quality components.

High-Risk Activities

Ventmann UK Ltd. considers the following areas as potentially higher risk:

  • Sourcing of raw materials or manufactured components from international suppliers where labour regulations may differ.
  • Third-party logistics and warehousing services.

These areas are regularly monitored to ensure compliance with ethical standards and our supplier code of conduct.

Responsibility for the Company’s Anti-Slavery Initiatives

1.1 Policies:

The Managing Director is responsible for creating, implementing, and reviewing company policies related to ethics, labour practices, and supplier compliance. Policies are reviewed annually to reflect current legislation and best practices.

1.2 Risk Assessments:

The Operations Manager conducts regular risk assessments concerning human rights and modern slavery within our supply chain, using a supplier evaluation process based on region, sector, and transparency.

1.3 Due Diligence:

The Procurement Department is responsible for conducting due diligence on all suppliers and partners to ensure compliance with the Modern Slavery Act 2015 and ethical business standards.

1.4 Management Review:

Senior management reviews supplier performance and internal compliance annually to ensure continued adherence to our anti-slavery principles.

Training

To ensure a strong understanding of modern slavery risks, all employees involved in procurement, supply chain management, and operations receive training to identify warning signs and report concerns appropriately.

Policies

Ventmann UK Ltd. is fully committed to ethical conduct and transparency throughout our operations and relationships.

The following policies support our efforts to prevent modern slavery and human trafficking:

2.1 Whistleblowing Policy:

Encourages all workers, customers, and business partners to report concerns regarding unethical conduct or suspected modern slavery without fear of retaliation.

2.2 Employee Code of Conduct:

Outlines the behaviour and ethical standards expected from all employees representing Ventmann UK Ltd., promoting fairness, respect, and accountability.

2.3 Corporate Social Responsibility (CSR) Policy:

Summarises how we manage environmental impacts, work responsibly with suppliers, and contribute positively to our community.

2.4 Supplier Code of Conduct:

Defines our expectations for suppliers regarding labour standards, human rights, and ethical trading.

Due Diligence Processes for Slavery and Human Trafficking

Ventmann UK Ltd. undertakes due diligence when onboarding new suppliers and reviews existing ones regularly. Our process includes:

  • Building long-term relationships with trusted suppliers.
  • Requiring supplier declarations confirming compliance with the Modern Slavery Act.
  • Evaluating potential risks based on geographic location and industry.
  • Invoking sanctions or terminating relationships with any supplier failing to meet our ethical standards.

Performance Indicators

We measure the effectiveness of our efforts through:

  • 100% of procurement and operations staff completing annual modern slavery awareness training.
  • Annual supplier audits and compliance reviews.
  • Maintaining a zero-tolerance policy for non-compliance within our supply chain.

Review and Approval

This Modern Slavery and Human Trafficking Statement will be reviewed annually and updated as required to reflect legislative changes and improvements in best practices.

Ventmann UK Ltd. endorses this policy statement and is fully committed to its implementation.