MODERN SLAVERY STATEMENT

1. Policy Statement

At Certikin International Ltd we are committed to carrying out all our business operations responsibly, ethically and transparently. As such we have a zero tolerance approach to Modern Slavery and Human Trafficking within our business and supply chains.

This policy applies to all our stakeholders including agents, contractors, consultants, customers and suppliers.

2. Fluidra SA

As part of the Fluidra SA international group of companies we are fully committed to the Fluidra Code of Ethics. As a Group we are obligated by the principals of Honesty and Trust and Respect for Human Rights. The Code of Ethics is based on the 10 principals set out in the UN’s Global compact. It is our top level standard setting instrument and adherence to the Code is a condition of employment by Fluidra and consequently by Certikin.

The Code of Ethics is binding and has the full commitment of the Board of Directors.

3. Business Model

Certikin International is a company which imports and exports goods on a worldwide basis. We have a large network of suppliers both in the UK and worldwide. We sell products to a well established group of account holding companies.

4. Due Dilligence

Customers

The vast majority of our customers are account holding businesses and are visited by ourselves to ensure their business practices fit with Certikin’s commitment to ethical business operations and this statement. We have long standing relationships with the vast majority of our customers and regularly visit their places of business and view their working practices. All our account holding customers have been found to work ethically and responsibly and do not use slave/ forced labour or permit human trafficking. Our customers have good employment practices in line with all the stringent requirements of UK employment law.

Suppliers

We have a worldwide network of suppliers including Asia, USA as well as Europe. Prior to the SARS–Cov–19 global pandemic we visited the factories of our Asian suppliers in order to establish good business relationships and ensure the factories were run ethically and without forced, slave or child labour. We were satisfied the suppliers we visited had well run businesses with employees paid reasonable wages and employed on a voluntary, not forced, basis. The factories maintained satisfactory conditions for workers.

We have long standing relationships with our UK, EEA and US suppliers and have visited the vast majority of businesses and factories to ensure there is no forced or slave labour.

Once Covid-19 travel restrictions are removed we will continue to visit our suppliers and ensure these standards are maintained on a regular basis.

Code of Ethics for Suppliers

Fluidra SA and Certikin International Ltd have drawn up a Code of Ethics for Suppliers. By suppliers, we mean suppliers, contractors, subcontractors and any third parties who supply goods and services to Certikin International Ltd.

Our aim is to be as transparent as possible in our business dealings by establishing and maintaining a relationship based on trust with our suppliers. Fluidra and therefore Certikin has made a commitment to the United Nations Global compact and drawn up the Code of Ethics for suppliers in order to further our aims and build solid long standing relationships with our suppliers. We aim to create mutually beneficial partnerships in order to continuously improve our business, optimise our production processes and make our products and services better.

We strongly believe in disseminating our Corporate values and principles to our stakeholders to encourage them to operate ethically and responsibly. We pledge with our suppliers to comply with the principles established in the Universal Declaration of Human Rights, the Rights of the Child and the Declaration of the International Labour Organisation (ILO).

All our suppliers sign to agree to our Code of Ethics for Suppliers as a condition of doing business with us. They must declare that they are against all forms of slavery as well as forced labour as set out in the 4th Principle of the UN’s global Compact. Our suppliers must work to eradicate child labour, prohibiting the recruitment of child labour in accordance with the recommendation of the ILO.

Employees

Certikin International Ltd is an equal opportunities employer and does not discriminate on any of the protected characteristics included in the Equally Act 2010 and in accordance with its internal Employee Equality policy. In particular all our employees are protected against direct and indirect discrimination, harassment and victimisation.

Our aim is always to be an employer of choice and provide a safe and secure working environment with total freedom of employment, fair wages and reasonable working hours. The wellbeing of our employees is our primary concern, as has been demonstrated in the unprecedentedly challenging situation of the Global pandemic when we have facilitated a Covid safe workplace and hybrid working arrangements. We provide wellbeing services such as access to medical advice and counselling and plan to offer further benefits in the year ahead.

We would never countenance forced labour or child labour in our workforce.

5. Training

All our employees are trained on the principles of the Fluidra Code of Ethics as part of the on boarding process. The Code is regularly reviewed and training is refreshed. Our employees are also trained to respect, embrace and act in accordance with our Corporate values. In the coming year adherence to our corporate values will become part of our employee appraisal process. Employees are encouraged to raise any concerns about this policy, first with a line manager, director, the Compliance Manager or the Managing Director.

All employees are also trained to report concerns via the Fluidra Confidential Channel to the Group’s top level committee established to investigate concerns.

6. Responsibility

Responsibility for this policy lies with the Compliance Department. The Operations Director, Sales Director and Purchasing Manager have day to day responsibility for implementing the policy and ensuring it is effective in countering modern slavery and preventing Human Trafficking.

7. Authorisation & Monitoring

This statement is authorised by the Managing Director and the Board of Directors and will be monitored on an annual basis with the overarching responsibilities to ensure the Company policies are sufficient to eradicate modern slavery and human trafficking.