This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that the ADEY Group has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain for the financial year ending 31st December 2018.

The ADEY Group comprises the following companies:

Adey Holdings (2008) Limited;

Adey Innovation Limited

Adey Commercial Limited

Adey Innovation SAS (operating throughout Europe)

Adey Innovation LLC (operating in North America).

Where we refer to ADEY in this statement, we are referring to the ADEY Group as a whole and, where necessary, the relevant individual member of the ADEY Group. The structure of the ADEY Group means that the policies and practices described in this statement apply to all members of the ADEY Group without the need for additional management or administration to ensure compliance.

What is modern-slavery?

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. ADEY has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain. We undertake all practical steps to ensure that our standards are being implemented throughout the business of our suppliers and that local legislation and regulations are complied with.

Our Business

ADEY is the UK industry leading name in magnetic filtration, delivering best practice maintenance and protection products and services for domestic and commercial heating systems throughout the United Kingdom, Europe and North America.

Our Policies

At ADEY, we encourage openness and provide support to anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring that no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is, or may be, taking place in any part of our own business or in the businesses of any of our supply chains.

To support this, and to ensure that we are conducting business in an ethical and transparent manner, we have prepared and make use of a number of policies and practices. These include:

1. Recruitment policy: We operate a robust recruitment policy, including conducting all appropriate and required eligibility to work checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
2. Equal Opportunities and Diversity Policy: This policy explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act. Our employees are collectively and personally responsible for the communication, understanding and practical application of this policy. The policy explains how ADEY expects employees to behave towards one another, and anyone they come into contact with and also allows employees to report any concerns they may have in a confidential and protected manner. This policy is made available to all new employees, and to our supply chain and to any other interested parties upon request.
3. Training: All relevant employees are required to undertake training in respect of how to identify the warning signs of slavery and exploitation. This includes the training of our procurement team to enable them to ensure that suppliers are conducting their business in a way in which complies with the standards that we set.
4. Responsible Trading: We are committed to maintaining high standards amongst our suppliers. This includes them adhering to our Supplier Charter. We oppose the exploitation of workers and we will not tolerate forced labour, or labour which involves physical, verbal or psychological harassment, or intimidation of any kind. We will not accept human trafficking or the exploitation of children and young people in our business and undertake all reasonable and practical steps to ensure that these standards are maintained, including having contracts in place with suppliers that include suitable provisions that oblige our suppliers to ensure they are complying with our policies with regard to modern slavery and human trafficking. We also have the right where appropriate, to audit suppliers to ensure compliance with these obligations.

This statement was approved by the Board of Directors on 15th May 2019.

Signed:

John Vaughan

Chief Executive Officer

15th May 2019