This is Volution Group’s statement on anti-slavery and human trafficking in accordance with the UK Modern Slavery Act 2015 and constitutes our statement for the financial year ended 31 July 2022.

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 of 19 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.

Australasia: Simx, Ventair, Manrose.

Volution Group endeavours to ensure that slavery and human trafficking is not taking place within our employed workforce, or any of our supply chain.

Although we believe that our exposure to the risks of modern slavery is relatively low, 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 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; and
• Conducting physical Code of Conduct 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.

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.

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 2022. 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 physical audits are due to be conducted in the remainder of 2022 and in 2023. A review of modern slavery geographical risk will be conducted annually to ensure that any new risks are identified and acted upon swiftly.

Training

 

Modern Slavery awareness training was introduced across all of Volution’s brands in early 2022. Personnel who have a supplier-facing role are required to complete a 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.

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.

8 September 2022