Modern Slavery Policy

MODERN SLAVERY STATEMENT

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) for the financial year ending 31st May 2026.
Established in Birmingham over 80 years ago, we are a national business supplying a wide range of catering equipment across the UK.
Modern Slavery in all forms, whether slavery, servitude, forced or compulsory labour, or human trafficking (collectively, “Slavery”), is a crime and a fundamental violation of human rights. As a company we remain absolutely committed to ensuring that there is no form of Slavery in our business and supply chain. We share this ethos with our suppliers and business partners and we are dedicated to sustaining open and transparent relationships with them to ensure that the highest ethical standards are maintained regardless of where they are located.
The prevention, detection and reporting of human rights violations in any part of our business or supply chain is the responsibility of all those working for W.V. Howe Limited and we expect our Directors and Employees to maintain the utmost standards in conformity with these principles.
We source products from across the globe and recognise that this may involve sensitive countries and industries. Our suppliers play a critical role in our business, and our relationships with them are based on achieving the best performance, product delivery times, service and total cost in an ethical and sustainable manner. We undertake a mapping exercise of our supply chains by collecting information about our tier 1 suppliers. We should then seek to collect information on lower tiers to help understand where risks may be greater.
• W.V. Howe Limited has a zero-tolerance approach to any form of Slavery. We recognise that our responsibilities extend to our supply chain and are committed to enforcing and maintaining a supply chain process which sets out the minimum standards we expect our suppliers to abide by in connection with how they treat their workforce, legal and regulatory compliance, health and safety, business ethics and environmental standards. We propose setting targets for training and capacity building of staff about modern slavery issues, measuring changes in awareness of risk, appropriate decision making and swift action as appropriate, grievance procedures and whistle-blowing procedures for workers if cases or suspected cases are found, visibility, leverage and oversight of suppliers in relevant goods and services supply chains.
As a minimum, we expect our suppliers to comply with the following requirements:
• All workers are treated equally and without discrimination, migrant workers should be treated no less favourably than other workers performing the same or similar work. They should also be protected from any discrimination that would constitute a violation of human rights.
• All workers enjoy the protection of employment law. Migrant workers should have a legally recognised employment relationship with an identifiable and legitimate employer in the country where the work is performed.
• No fees are charged to migrant workers The employer should bear the full costs of recruitment and placement. Migrant workers are not charged any fees for recruitment or placement.

• All migrant worker contracts are clear and transparent. Migrant workers should be provided with written contracts in a language each worker understands, with all terms and conditions explained clearly, and the worker’s assent obtained without coercion.

• Policies and procedures are inclusive. Migrant workers’ rights should be explicitly referred to in
employer and migrant recruiter public human rights policy statements, relevant operational policies and procedures addressing human rights responsibilities.
• No migrant workers’ passports or identity documents are retained. Migrant workers should have free and complete access to their own passport, identity documents, and residency papers, and enjoy freedom of movement.
• Wages are paid regularly, directly and on time Migrant workers should be paid what they are due on time, regularly and directly.
• The right to worker representation is respected. Migrant workers should have the same rights to join and form trade unions and to bargain collectively as other workers.
• Working conditions are safe and decent. Migrant workers should enjoy safe and decent conditions of work, free from harassment, any form of intimidation or inhuman treatment. They should receive adequate health and safety provision and training in relevant languages.
• Living conditions are safe and decent. Migrant workers should enjoy safe and hygienic living
conditions, and safe transport between the workplace and their accommodation. Migrant workers
should not be denied freedom of movement, or confined to their living quarters.
• Access to remedy is provided. Migrant workers should have access to judicial remedy and to credible grievance mechanisms, without fear of recrimination or dismissal.
• Freedom to change employment is respected, and safe, timely return is guaranteed. Migrant workers should be guaranteed provision for return home on contract completion and in exceptional situations.
They should not, however, be prevented from seeking or changing employment in the host country on completion of first contract or after two years, whichever is less.
For any supplier who is found to be noncompliant with our policies, we will terminate our relationship unless conditions are immediately improved and compliance is restored.
W.V. Howe Limited is committed to training its employees on an ongoing basis. We provide training and guidance on what Slavery is, what preventative measures must be implemented and what steps should be taken in the event that any concerns are identified in our supply chain.
W.V. Howe Limited’s expectation and aim is to not tolerate any business that does not respect basic human rights.

Signed:

Becci Peake
Managing Director
January 2026