Modern Slavery Act

Introduction
This statement sets out Axter Ltd’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year January – December 2020.

Axter recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

Axter is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Axter Ltd.

Axter Ltd is a wholly owned subsidiary of Axter SA in France. Axter Ltd undertakes waterproofing specification design and system material supply on behalf of its clients and customers and is operational in all new construction and refurbishment sectors in the United Kingdom and Ireland. The nature of Axter Ltd’s supply chain is uncomplex, streamlined and carefully managed by our Sales and Logistics and Procurement Managers.

Countries of operation and supply

Axter currently operates in the following countries:

• The United Kingdom of England, Scotland, Wales and Northern Ireland and the Republic of Ireland.

The following is the process by which Axter assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

• mapping the supply chain broadly to assess material or geographical risks of modern slavery and human trafficking;
• evaluating the modern slavery and human trafficking risks of each new supplier as part of a more general human rights or labour rights assessment process.

High-risk activities

Following risk assessment, Axter Ltd has identified no activities within its operational function or supply chain that are considered to be at high risk of slavery or human trafficking

Responsibility

Responsibility for Axter's anti-slavery initiatives is as follows:

• Policies: The Managing Director and Operations Manager (Administration & HR) assisted by specialist Legal representatives.
• Risk assessments: The Managing Director and Operations Manager (Administration & HR) assisted by specialist Legal representatives are responsible for Company human rights and modern slavery risk analysis.
• Investigations/due diligence: Alex Delbrouque, Procurement Manager. Responsible for product and material sourcing, new supplier initiatives and monitoring the fabrication of raw materials into final products. Katie Day, Sales and logistics Manager. Responsible for the transport and flow of goods and services.
• Training: Annual training is provided to all employees in Axter Ltd anti-slavery and human trafficking policy and initiatives.

Relevant policies

Axter operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations

• Whistleblowing policy - Axter encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, Axter. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Axter's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
• Employee code of conduct - Axter's code makes clear to employees the actions and behaviour expected of them when representing Axter. Axter strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
• Supplier code of conduct - Axter is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Axter works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of Axter's supplier code of conduct will lead to the termination of the business relationship.
• Recruitment/Agency workers policy - Axter uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
• Axter Code of Ethics – Axter has a clear Code of Ethics policy that is freely distributed throughout the organisation, its supply chain and to clients and customers.

Due diligence

Axter undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. Axter's due diligence and reviews include:

• mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
• evaluating the modern slavery and human trafficking risks of each new supplier as part of a more general human rights or labour rights assessment;
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• conducting supplier audits or assessments through, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• creating an annual risk profile for each supplier;
• taking steps to improve substandard suppliers' practices, including providing advice to suppliers through and requiring them to implement action plans;
• participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular such as participation in "Stronger together" or "Ethical trading" initiatives;
• using an ethical supplier database, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
• invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators

Axter has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, Axter is:

• requiring all staff to have completed training on modern slavery annually;
• developing a system for supply chain verification, whereby Axter evaluates potential suppliers before they enter the supply chain; and
• reviewing its existing supply chains, whereby Axter evaluates all existing suppliers.

Training

Axter requires all staff within Axter to complete training on modern slavery annually.

Axter's modern slavery training covers:

• our business's purchasing practices, which influence supply chain conditions, and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;
• how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within Axter;
• what external help is available, for example through the Modern Slavery Helpline;
• what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
• what steps Axter should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from Axter's supply chains.

Awareness-raising programme

As well as training staff, Axter raises awareness of modern slavery issues by circulating information to staff on:

• the basic principles of the Modern Slavery Act 2015;
• how employers can identify and prevent slavery and human trafficking;
• what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within Axter; and
• what external help is available, for example through the Modern Slavery Helpline.

Board approval

This statement has been approved by Axter's board of directors, who will review and update it annually.

Director's name: Phillip Wilcox-Moore

Date: January 2020