Modern Slavery Statement

(For the financial year ending 31 December 2023)

INTRODUCTION
Gledhill Building Products Limited (“we” “us” “the Company”) are committed to acting ethically and with integrity in all our business dealings and relationships. We are committed to implementing and enforcing effective systems and controls to ensure that human trafficking and slavery is not taking place anywhere in our own business or in any of our supply chains.
This statement details the steps taken by the Company during the financial year ending 31 December 2023 to prevent slavery and human trafficking occurring in any of our businesses or supply chain.
In preparing the statement we have considered the obligations placed on us as a result of the Modern Slavery Act 2015 and the risks the business is exposed to as a result of operations of its business.
It is expected that all personnel responsible for the sourcing and specification of materials for use in our products act with Integrity to ensure that no action taken by the business is likely to adversely impact the human rights of people working in all levels of our supply chain locally and globally.

ORGANISATIONAL STRUCTURE
We are a market leading supplier of domestic and commercial heating products primarily to the UK market. We are a part of the Groupe Atlantic (Group), which is the ultimate parent company. The Group has its head office in France and has over 13,000 employees across 28 manufacturing sites worldwide.

OUR SUPPLY CHAINS
The Company’s sales market continues to be UK focused with the supply market being global. Our critical suppliers are predominantly located in continental Europe as well as the UK. In 2022 the GA UK Operating division implemented a Supplier Performance Management & Development tool to assist with all aspects of supplier risk management, which was adopted by Gledhill at the start of 2024. This tool has a module which uses algorithms to determine the level of ESG risk attributable to individual supplier’s dependent on a number of factors including geography, human rights, labour rights and business ethics.
• Suppliers are only able to trade with us after successfully completing an initial Pre-Qualification Questionnaire (PQQ) covering the strategic, critical issues outlined previously. Failure to complete this questionnaire satisfactorily disbars suppliers from being able to work with us.

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. No new policies relating to these topics have been introduced during the financial year ending 31 December 2023.
Existing policies and statements listed below are reviewed on a regular basis to ensure compliance with relevant law and ethical responsibilities.
• Recruitment Policy: the policy outlines the business approach to recruitment, working with recruitment agencies and agency workers and the provision of documentation contingent to offers of employment being made. Contracts of employment provide details of how workers can terminate employment and on overtime expectations.
• Bribery Policy: The policy sets out clear guidance in respect of prevention of bribery and corruption by or involving our workers and includes information on our workers’ obligations and potential liabilities.
• Interest Disclosure Policy (Whistleblowing) The policy encourages workers to report any concerns about wrongdoing or dangers internally through the proper channels. The Company continues to promote individuals to speak and raise concerns internally and disclose information which the individual believes to illustrate illegal unethical behaviour or other serious malpractice, including any matters relating to modern slavery.
• CSR Policy: An overarching policy describing how the business meets or exceeds its obligations on matters relating to the environment, ethical trading
• DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
The Company continues to maintain internal accountability standards and procedures for employees and contractors for failing to meet company standards regarding modern slavery and human trafficking. The following approaches are used by the Company to identify and mitigate risk and no other action has been implemented during the financial year ending 31 December 2023:
• Site Audits & Business Reviews: Gledhill personnel will occasionally visit new or existing suppliers to assess their capabilities.
• Eligibility for Working in the UK: When recruiting new employees into the business and when using the services of agency personnel, the HR function ensures that all agency personnel and new permanent recruits have been correctly vetted and that their eligibility for employment in the UK has been established.

TRAINING & AWARENESS
• To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff via an easy to access online platform. The business is a member of both Sedex and Ecovadis platforms and from time to time will draw down on the resources provided through these solutions.

FURTHER STEPS
The Company is constantly re-evaluating its processes to ensure there is no slavery or human trafficking in its supply chain. Over the coming year, the Company will endeavour to:
• Raise the profile of Modern Slavery obligations as part of new employee induction processes.
• Ensure we participate at external modern slavery events and workshops (where possible).
• Review our internal training available to our employees.
• Explore any additional online tools which would assist us in the assessment of our supply Base in relation to CSR obligations.
• Provide feedback to suppliers and guide them in addressing any areas of concern.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2023.



Signed by: Steve Hairsine, Chief Executive Officer, Gledhill Building Products Ltd GA-UK Division
Date: 28.06.2024