DIRECT HEATING 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

Training described

Your front line staff Human resources Procurement staff

Worker engagement and working conditions

Your suppliers Professional auditors Workers within your organisation Businesses in your industry or sector

Social audits

Third party audit arranged by your organisation Third party audit arranged by your supplier Announced audit

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app Through trade unions or other worker representative groups

Other monitoring

We have an Online Risk Assessment which allows us to assess a far larger number of suppliers than site-auditing alone.

Demonstrated progress

Yes. Our statement provides updates against the stated objectives for each reporting year and confirms the key objectives for the year ahead. This way we can demonstrate how we are improving year on year. We publish performance figures for training completion, which is our stated primary KPI. We also confirm whether any incidences of modern slavery have been identified in our business or supply chain during the year under review.

Reported risks and mitigations

• Risk: Workers in our manufacturers' supply chains based in countries with a high risk rating in the Global Slavery Index, the Corruption Perceptions Index and the Worldwide Governance Indicators (WGI)
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers Tier 3 suppliers and below
• Group: Women Migrants Refugees Children
• Location: Bulgaria Brazil China Czechoslovakia Spain Greece Hungary Israel India Italy South Korea Latvia Poland Portugal Romania Russia Thailand Turkey Vietnam South Africa Taiwan
• Mitigation: Our centrally-controlled suppliers of products for resale go through a due diligence process which comprises three stages. Firstly, a contractual commitment to our ethical requirements through reference to our Supplier Commitments in the standard trading agreement. Secondly, an assessment of compliance with our Supplier Commitments through an ‘Online Risk Assessment’. A third stage of assessment is in place for manufacturers of our own-brand (or no-brand) products; a site audit programme.
• Risk: Workers in our manufacturers' supply chains for product types which are more exposed to slavery risk (using more seasonal or manual labour)
• Location: Brazil United Kingdom Russia Vietnam
• Risk: Labour agency workers in our own business, particularly in our large distribution centres in the UK which use a higher volume of temporary labour and in-house labour agency supervisors.
• Area: Within your own operations
• Group: Other vulnerable groups
• Location: United Kingdom
• Mitigation: All agencies used by the Group’s distribution centres, which employ a high level of manual labour, undergo checks. Firstly, a contract must be in place which details our expectations around their own due diligence. Secondly, the agency must provide a ‘sign off sheet’ for each worker coming to our sites, including their name and photograph. The agency workers must bring their identification documents on their first day so that our business can check them against the sign off sheets.