Modern Slavery Statement

This statement applies to all companies within and associated to PureH2O Ltd hereon referred to as PureH2O. The information included in the statement refers to the financial year Jan 25 to Dec 25.

1. ORGANISATIONAL STRUCTURE
   PureH2O is a private Company with limited liability. It has one office based in Woking, Boundary Business Centre. It has two Directors and no other affiliated companies in the group.The Company is engaged in the manufacture, installation and maintenance of water purification systems. We engage with our customers once annually for service requirements and offer out of service maintenance when required.The labour supplied to the PureH2O Ltd in pursuance of its operation is carried out in Woking and at clients offices or homes throughout England.
2. DEFINITIONSPureH2O Ltd considers that modern slavery encompasses:
   • Human trafficking;
   • Forced work, through mental or physical threat;
   • Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
   • Being dehumanised, treated as a commodity or being bought or sold as property;
   • Being physically constrained or to have restriction placed on freedom of
3. COMMITMENT
   PureH2O acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. PureH2O understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.The PureH2O does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.No labour provided to the PureH2O in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. PureH2O strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom. As a matter of course, we carry out DBS checks on all staff.
4. SUPPLY CHAINS
   In order to fulfil its activities, the PureH2O’s main supply chains include those related to the supply of goods in the United Kingdom. 90% of components are made within 3 miles of the offices in Woking making use of manufacturing companies with CNC tooling and sheet metal facilities. Our printed circuit boards are manufactured in Reading. We minimise importing products from China opting to use local manufacturers, supporting local jobs where we know the owners and staff and make regular visits to maintain our relationship and Quality Control.
5. POTENTIAL EXPOSURE
   PureH2O considers to have no exposure to the risk of slavery and human trafficking because of our close relationship with local manufacturers.In general, PureH2O considers its exposure to slavery/human trafficking to be exceptionally low. Nevertheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
6. IMPACT OF COVID-19
   During the reporting period covered by this statement, the COVID-19 pandemic had taken hold. For the two years in which the UK was placed into periodic lockdown it created several challenges for PureH2O as it did for others across the nation. These lessons will be retained for future possibilities of similar eventsPureH2O concluded that the COVID-19 pandemic did not adjust the risk of modern slavery to a level above that which existed before the pandemic, which is as set out under ‘POTENTIAL EXPOSURE’ above. During the pandemic, PureH2O employees still had access to the grievance procedure to raise any concerns that they may have had.In line with emergency legislation passed by the Government, employees were paid Statutory Sick Pay during periods of self-isolation where it has not been possible to agree a temporary period of homeworking. PureH2O took the decision from the outset of the pandemic to ensure that all of the workforce who were required to self-isolate in accordance with public health guidelines continued to receive furlough pay during their absence.PureH2O modern slavery risks were subject to the same monitoring procedures during the pandemic as at all other times.
7. STEPS TAKEN
   PureH2O carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.PureH2O has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.In accordance with section 54(4) of the Modern Slavery Act 2015, PureH2O has taken the following steps to ensure that modern slavery is not taking place:
   • Measures are in place to identify and assess the potential risks in its supply chains and given that over 90% of components are manufactured within 3 miles of our office.
8. KEY PERFORMANCE INDICATORS
   PureH2O has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in PureH2O or its supply chains.
   • 1 No. On site meetings and inspection of suppliers premises and labour each year
   • 1 No. Unannounced spot checks of labour employed in our suppliers premises each year.
9. POLICIES
   PureH2O has the following policies which further define its stance on modern slavery in addition to the legal checks required. Documentation on the employee’s personal file will be help for at least 2 years after the individual has left. Periodic reviews for right to work of all workers including agency temporary and seasonal employees takes place.
10. TRAINING
    PureH2O makes reference to its stance on modern slavery during the induction of all new staff. Staff are checked for their rights to work in the UK with photographic proof of identity, independent bank accounts in their names.Our employees will be made aware of indicators, identified by the ILO, that highlight the circumstances where forced labour may be found. Namely:
    • Abuse of vulnerability
    • Deception
    • Restriction of movement
    • Isolation
    • Physical and sexual violence
    • Intimidation and threats
    • Retention of identity documents
    • Withholding of wages
    • Debt bondage
    • Abusive working and living conditions
    • Excessive overtime

    The ILO highlights agriculture, construction, manufacturing, extractives, entertainment industries and domestic work as having the highest risk of forced labour. In 2012, the ILO estimated 56% of forced labour victims were found in the Asia-Pacific region, but that Central and Eastern Europe and Africa have the highest prevalence of forced labourers at 4.2 and 4.0 per 1,000 inhabitants. The evidence from the ILO, the US Department of State and Labour and a range of civil society and trade unions show that forced labour is found in all regions of the world and in a wide range of industries.

    Pureh2O recognises the need to consider the risk of forced labour, irrespective of the industry or countries in which we operate or from which we source some component parts. Approximately 10% of parts are sourced from Asia and we therefore build close working relationship with those suppliers in an effort to try and understand the background to their business and to mitigate the chance of buying parts from entities that may engage in forced labour.

    PureH2O staff are encouraged to read the Ethical Trade Initiative to further their understanding of the circumstances in which slavery manifests itself.

    Formal Training is implemented using a third party for the purpose of impartiality, professionalism and keeping up with changes to legislation that may otherwise be missed in a less formal internal process.

11. SLAVERY COMPLIANCE OFFICER
    PureH2O has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to PureH2O obligations in this regard.This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Date of approval 01/07/2025
Signed by the Board of Directors
R Wiltshire & N Jacobs

1. Modern Slavery and Human Trafficking Policy
   Outlines the company’s commitment to preventing slavery and human trafficking in its operations and supply chains. Includes definitions, scope, and reporting mechanisms.
2. Supplier Code of Conduct
   Sets expectations for ethical behaviour and labour standards for all suppliers, including zero tolerance for forced or child labour, and the right to freely chosen employment.
3. Whistleblowing Policy
   Provides a confidential mechanism for employees and third parties to report concerns about unethical behaviour, including suspected modern slavery.
4. Recruitment and Employment Policy
   Ensures fair hiring practices, prohibits the charging of recruitment fees, and requires proof of legal right to work. Includes safeguards against exploitation in agency worker contracts.
5. Ethical Trading Policy
   Defines the company’s approach to fair labour practices, human rights, and transparency in its trade and sourcing relationships.
6. Training and Awareness Policy
   Ensures staff (especially those in procurement and HR) are trained to identify signs of modern slavery and understand how to respond appropriately.
7. Due Diligence and Risk Assessment Policy
   Outlines how the company assesses and monitors modern slavery risks in its operations and supply chains, and how it takes action to mitigate them.
8. Corporate Social Responsibility (CSR) Policy
   Communicates the company’s broader ethical stance, including human rights, community engagement, and sustainability, reinforcing its anti-slavery position. 

PureH2O Ltd Assessment criteria for purchasing practices that may create pressures on our suppliers that could lead to modern slavery.

1. Conduct Supplier Risk Assessments
   • Evaluate suppliers based on sector, geography, and labour practices.
   • Focus on countries or industries with a high prevalence of forced labour.
   • Include modern slavery risk factors in supplier audits.
2. Review Contract Terms and Lead Times
   • Assess whether short lead times, last-minute changes, or unrealistic cost expectations force suppliers to exploit workers to meet demand.
   • Ensure purchasing timelines are reasonable and do not lead to abusive subcontracting.
3. Engage Suppliers in Dialogue
   • Discuss how your purchasing practices impact their operations and workforce.
   • Encourage transparency by building long-term relationships and open communication.
4. Map the Supply Chain
   • Go beyond Tier 1 suppliers to understand the entire supply chain, especially in vulnerable areas.
   • Identify where labour-intensive or outsourced work occurs.
5. Audit Labour Conditions
   • Conduct ethical audits or require third-party social audits focused on working conditions, recruitment practices, and worker treatment.
   • Use unannounced visits when appropriate.
6. Include Modern Slavery Clauses in Contracts
   • Require suppliers to comply with anti-slavery legislation and allow for regular audits or site inspections.
   • Include termination clauses for breaches.
7. Monitor Payment Practices
   • Avoid late payments or sudden price cuts that may pressure suppliers to cut labour costs unfairly.
   • Ensure fair pricing that supports decent wages and working conditions.
8. Employee Training on Ethical Procurement
   • Train procurement staff to understand the impact of purchasing decisions on supplier labour practices.
   • Include modern slavery risks in decision-making processes.
9. Use Supplier Self-Assessment Questionnaires
   • Distribute regular surveys assessing suppliers’ labour policies, subcontracting practices, and worker protections.
   • Use responses to identify risk patterns and plan follow-ups.
10. Implement KPIs and Reporting Mechanisms
    • Track and report on indicators such as audit non-compliance rates, worker grievances, and supplier improvement plans.
    • Include supplier performance on ethical issues in procurement evaluations.

PureH2O are committed to implementing an SLA with suppliers that engages with and sets out clear objectives and paths to assess and identify the circumstances in which employees may be coerced into conditions of slavery. Our aim is to develop a framework for remediation through which our supply chain will engage and encourage openness with and fair treatment of employees.

• Freedom to choose their place of work
• Freedom to choose their place of habitation
• Freedom to choose to join a trade union body or equivalent work place representation

1. Training and capacity building of staff about modern slavery issues
   • Implemented at Induction
   • 3^rd Party training to be implemented annually during 2025
2. Measuring changes in awareness of risk
   • Self assessment to be completed annually
3. Appropriate decision making and swift action as appropriate
4. Grievance procedures and whistle-blowing procedures for workers if cases or suspected cases are found
   • Introduced during the induction of new members of staff
   • Reinforced through the access to the company handbook on line and in print
5. Visibility, leverage and oversight of suppliers in relevant goods and services supply chains
   • 1 x formal annual review meeting
   • Informal impromptu visit to suppliers every 6 months