Modern Slavery and Human Trafficking Policy

1. Introduction and Policy Statement

1.1. The Modern Slavery Act 2015 (the ‘Act’) mandates that City Electrical Factors Limited ('CEF') prepares a slavery and human trafficking statement each financial year.

1.2 Modern slavery and human trafficking in all their various forms and guises are a crime in the UK and much of the world and a violation of fundamental human rights.

1.3 CEF have a zero-tolerance approach to modern slavery and human trafficking and are committed to acting ethically and with integrity in all activities and business relationships and we expect our supply chain, contractors, employees and all other business partners to commit to the same, including implementing and enforcing effective systems and controls to prevent and detect modern slavery.

2. Our Business

2.1 The economic, social and environmental footprint of our business activity is a fundamental consideration in CEF’s commitment to responsible and sustainable business growth.

2.2 CEF is one of the UK’s largest electrical wholesalers with a UK network of almost 400 branches. Customers can also place online orders up until 8pm for next day delivery at cef.co.uk with access to almost 30,000 products from over 200 leading suppliers.

2.3 By combining product and brand choice with local personal service, technical support and free delivery, CEF is dedicated to being the UK’s most helpful electrical wholesale network.

3. Responsibility For The Policy

3.1. The Directors and senior management team of CEF have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all persons working for us or on our behalf in any capacity comply with it.

3.2. The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all persons working for us or on our behalf in any capacity (including our employees, suppliers, workers, directors, agents, distributors and all third party business partners).

3.3. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate training on it and the issue of modern slavery in supply chains.

4. Commitment

4.1. CEF are implementing and enforcing a number of measures, policies and controls both internally and externally to ensure compliance with the requirements of the Modern Slavery Act 2015.

4.2. Training on this policy and the risk our business faces from Modern Slavery and Human Trafficking forms part of the induction process for all individuals joining the business and an e-learning module is being created for all existing staff employed in a purchasing function. Regular refresher training will be provided as required.

4.3. The issues surrounding Modern Slavery and Human Trafficking have been added to the CEF Handbook which is available to all employees.

4.4. The CEF Supplier’s Charter and Terms and Conditions of Purchase have been amended to encompass Modern Slavery and Human Trafficking and copies are available to our suppliers on request.

5. Compliance

5.1 All persons working for us or on our behalf in any capacity must:

5.1.1 read, understand and comply with this policy, and avoid any activity that might lead to, or suggest, a breach of this policy;

5.1.2 Notify their immediate manager as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur in the future; and

5.1.3 Raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

6. Breaches Of Policy

6.1. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

6.2. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

7. Ongoing Review

7.1. CEF will review both its supply chains and external operations and its internal operations on an ongoing basis to check compliance with the above policy, and to check that our policy is being implemented effectively.