Modern Slavery Act
VOLUTION GROUP PLC AND SUBSIDIARY COMPANIES (“Volution Group”)
MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT
ABOUT VOLUTION GROUP
This is Volution Group’s statement on modern slavery and human trafficking in accordance with the UK Modern Slavery Act 2015 and constitutes our statement for the financial year ended 31 July 2023.
Volution Group plc has a Premium Listing on Main Market of the London Stock Exchange (LSE: FAN) and is the parent company of the Volution Group of companies. The Group is a leading international designer and manufacturer of energy efficient indoor air quality solutions.
Volution Group comprises 22 key brands across three regions:
UK: Vent-Axia, Manrose, Diffusion, National Ventilation, Airtech, Breathing Buildings, Torin-Sifan. Continental
Europe: Fresh, PAX, VoltAir, Kair, Air Connection, Rtek, inVENTer, Ventilair, ClimaRad, ERI Corporation, VMI, I-Vent.
Australasia: Simx, Ventair, Manrose, DVS
For more information, please go to: www.volutiongroupplc.com
Volution Group works hard to ensure that slavery and human trafficking is not taking place within our employed workforce, or any of our supply chain. We believe that our exposure to the risks of modern slavery is relatively low, however, we are not complacent. We understand that, if we are to be successful in delivering our strategy for growth, then we must make sure that we interact with our employees, customers, suppliers, and others properly.
That is why we have rolled out a Code of Conduct across Volution Group which sets out our commitment, within Volution Group and externally, to the value and importance that we place on honest, ethical, and lawful conduct in all our business dealings.
Volution Group globally has a substantial and wide-reaching supply chain with a significant number of suppliers across 35 countries. Consistent with the principles set out in our Code of Conduct, we prohibit forced labour, child labour, and discrimination within our supply chain. We ensure, as is reasonably practicable, that our suppliers have controls in place to uphold our commitment to combatting slavery and human trafficking.
We recognise that the risk of Modern Slavery is present in every country in the world, and therefore we have put in place robust measures to counter this risk. It is also the case that some geographical locations and industries have a higher risk of Modern Slavery malpractice, and due to this we have chosen to take a risk-based approach in our efforts to eliminate malpractice from our supply chains.
We take appropriate steps to endeavour to ensure that there is no modern slavery or human trafficking in our supply chains, including:
- requiring new suppliers to declare as part of our supplier approval processes, that they are not involved in modern slavery or human trafficking, including confirmation of their understanding and commitment to the principles of the UK Modern Slavery Act and which are included within our Code of Conduct;
- requiring our current incumbent supply base to also declare their commitment and compliance to the principles set out in our Code of Conduct;
- conducting both desktop and in-person audits at the production centres for suppliers based in higher risk geographical areas, or if there is reason to believe that it may be required for any supplier. Geographical risk is assessed using the Global Slavery Index;
- requiring suppliers with whom we have a spend greater than £100,000, of which there were 197 in 2023, to have an additional level of scrutiny. The suppliers within scope should either have a publicly available statement on their approach to tackling Modern Slavery, or provide information on what they are doing, or planning to do, to combat Modern Slavery; and
- requiring service providers who work on our sites, or do any work on our behalf, to provide details on how they ensure that none of their employees could be victims of Modern Slavery. The scope of this requirement includes cleaning companies and temporary labour providers.
If any supplier is deemed to be in breach of our Code of Conduct, they will be required to complete a Corrective Action Plan. Continued non-compliance will result in the supplier being struck-off our approved list. There were no suppliers found to be in breach of our Modern Slavery standards in FY23. However, one supplier based in the Far East did not engage with us and we have now severed ties.
To ensure our employees are not subject to undue influence and are treated with dignity and respect, Volution Group has robust human resource policies and procedures in place across all its operations.
Volution Group is committed to ensuring that all staff receive fair remuneration for the job they perform and undertakes regular reviews of terms and conditions across the workplace.
Volution Group adheres to the payment of the National Living Wage in the UK and all compulsory minimum wage premiums as set by governments.
Volution Group also has robust recruitment processes, which include verifying the identity of each employee and their right to work in each country before commencing employment. All temporary workers are supplied through reputable recruitment agencies, which have been subject to thorough due diligence of their practices.
Volution Group’s Whistleblowing facility is designed to make it easy for employees to make disclosures, without fear of retaliation.
ASSESSING AND MANAGING RISK
A number of physical supplier audits were carried out in the financial year ending 31 July 2023. Based on the Global Slavery Index, our assessment work has identified more countries deemed to have a moderate to high modern slavery risk. Suppliers based in a country with a moderate to high modern slavery risk now require a physical audit.
Further in-person audits are due to be conducted in the remainder of 2023 and in 2024. A review of modern slavery geographical risk will be conducted annually to ensure that any new risks are identified and acted upon swiftly.
Personnel who have a supplier-facing role are required to complete a Modern Slavery awareness training module and demonstrate that they have understood the dangers that modern slavery poses to the business, and the devastating impact it has on its victims. The level of completion of our Group-wide training modules is a KPI against which we track our performance and is reported to the Audit Committee twice a year.
This statement has been approved by the Volution Group plc Board of Directors on behalf of Volution Group. A new statement will be published each year on the corporate website www.volutiongroupplc.com.
Ronnie George Chief
Volution Group plc
3 October 2023