SCREWFIX SPARES LIMITED

Policies described

Freedom of workers to terminate employment Freedom of movement Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits the use of worker-paid recruitment fees Prohibits compulsory overtime Prohibits child labour Prohibits discrimination Prohibits confiscation of workers' original identification documents Provides access to remedy, compensation and justice for victims of modern slavery Other

Training described

Your whole organisation Your front line staff Procurement staff Your suppliers Other

Worker engagement and working conditions

Your suppliers Workers within your organisation Workers within your supply chain

Social audits

Audit conducted by your staff Third party audit arranged by your organisation Announced audit

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app

Other monitoring

Roll out of app enabling colleagues to upload photos and feedback from factory visits. Enabling insight into conditions and potential issues outside of the audit process.

Actions addressing ILO indicators

Financial remediation, including repayment of recruitment fees Other

Demonstrated progress

All goods for resale production sites supplying us with finished goods are required to hold an active membership with one of our nominated ethical audit platforms such as Sedex and amfori BSCI. — 84% of suppliers complied (2024: 82%). — For OEB suppliers, the figure was 95% (2024: 95%) and 82% for non OEB (2024: 79%). Goods not for resale suppliers accounting for 76% of in-scope spend had been EcoVadis assessed in 2025. 82% of those who re-assessed either improved or maintained their score.

Reported risks and mitigations

• Risk: An audit in India found overcrowded, unsuitable worker housing and inconsistent attendance records, preventing verification of working hours, overtime, and wage payments.
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers
• Group: Other vulnerable groups
• Location: India
• Mitigation: The factory demolished the existing accommodation and allocated new accommodation for their workforce. Their computerised system for recording attendance, overtime and wages, which had been temporarily disconnected, was reinstated and evidence of record-keeping was shared with us ahead of the follow-up audit. The Ethical Compliance Team held monthly meetings with the factory to review the corrective action plan and monitor improvements and upgrades. All non-compliances closed.
• Risk: A third-party audit and worker interviews identified that one supervisor at a site in Malaysia required workers to fill in a logbook whenever they wished to use the toilet.
• Location: Malaysia
• Mitigation: The supervisor was instructed to discontinue use of the logbook. Workers were informed that use of the logbook had been discontinued. The factory has confirmed that this practice has been discontinued. A follow-up audit will be conducted in 2026 to confirm implementation of the corrective action, including worker interviews
• Risk: An audit in China found excessive working hours and delayed overtime payments due to a non-compliant banking hours system, causing workers to wait extended periods for overtime pay.
• Location: China
• Mitigation: Overtime wages are now paid at the end of each month, in compliance with the law. The factory implemented additional controls to monitor working hours and prevent excessive overtime. The supplier has made changes to its ethical sourcing practices to better align with the Kingfisher Human Rights Policy. A third-party follow-up audit verified that the corrective actions had been implemented. Worker interviews confirmed that overtime wages are now paid in line with local law.