Modern Slavery Statement 2022

Table of Contents

  1. Statement………………………………………………………………………………………………………………………… 3

Forward Looking Statement      8

1.  Statement

The UK Modern Slavery Act 2015 came into effect on 29th October 2015. The law requires manufacturers and retailers doing business in the UK which supply goods or services and have an annual turnover exceeding £36 million to disclose information regarding their policies to eradicate slavery and human trafficking from their supply chain and within their business.

The Vaillant Group understands that slavery, servitude, forced labor and human trafficking (Mod- ern Slavery) is a global and growing issue given the rapid rise in global migration, existing in every region in the world and in every type of economy, whether industrialized, developing or in transition. The Vaillant Group is very proud of the integrity measures we take in this regard. The Vaillant Group efforts to eradicate slavery and human trafficking in its supply chain and own business include the following:

1.1.   About Village Heating

With over 24 years’ experience, we are one of London’s leading plumbing, heating, electrical and boiler repair service providers. We have a high customer satisfaction rate and always strive to go the extra mile to ensure our customers are satisfied and happy with our work. From offering extended warranties to ensuring that you receive that personal service, VHL is fully accredited and insured. Our engineers are vetted and have been with us in most cases for decades. Our systems are regularly audited and all data kept is in strict compliance with the Data Protection laws. Our brand name is our most important asset and we make sure that it reflects our honesty and integrity.

  • Products and services

Village Heating markets the entire spectrum of boiler breakdown, service and repairs. The main fields of activity for the company’s products are commercial and domestic properties.

  • Production network and Quality Management

Village Heating manufactures products in a total of ten locations – eight of these are in Europe, one in Turkey and one in China.

Production includes the manufacturing of all performance- and quality-relevant key components as well as the final assembly of all devices, plus comprehensive testing of the performance attributes.

1.2.   Our Policies

At Village Heating we have embedded our commitment to addressing slavery and human trafficking into a set of policies which are an integral part of how we shape our operations and business relations.

  • Our Code of Conduct sets the foundation for the values, rules and behavior we aim for at Vaillant Group and reference for any form of relationship – with colleagues, customers, suppliers or external stakeholders.
  • Our commitment to the Principles of United Nations Global Compact stresses that Vaillant Group applies a comprehensive and ambitious approach to the most urgent global challenges. We report our progress on an annual basis.
  • Our human rights policy statement expresses our policy of observing and strengthening hu- man rights as a fundamental part of our corporate ethos.
  • Our Supplier Code of Conduct lays out our expectations and requirements towards our suppliers with regards to health and safety, environment, labor, human rights and compliance

1.3.   Our Risk Assessment

Village Heating `s Integrated Risk and Opportunity Management (Integriertes Risiko- und Chancen- management (RCMS)) is an early warning system that closely monitors potential risks and opportunities. The holistic approach combines financial, regulatory, physical and reputational risks and is part of our regular internal management reporting system.

To adequately address the concerns of our business partners, customers and the general public we systematically conduct stakeholder dialogues. These guide us in pro-actively identifying po- tential needs for information or action.

In addition, in 2021 we conducted a comprehensive human rights risk analysis for own operations in cooperation with an external partner. This risk analysis consisted of identifying and describing the human rights risks, assessing the human rights risks and prioritizing them. We reviewed the effectiveness of already established control measures and are developing a roadmap for adapting already existing control measures, establishing new control measures and we are discussing the results with involved departments. We will review this risk analysis of our own operations on a regular basis.

Furthermore, we evaluate the countries in which we source our goods with an eye to potential risks according to the Worldwide Governance Indicators of the World Bank. The World bank re- ports on individual and aggregate governance indicators for over 200 countries and territories for six dimensions of governance: voice and accountability; political stability and absence of violence; government effectiveness; regulatory quality; rule of law; and control of corruption. In this risk analysis we also include potential human rights risks in our high risk sourcing countries according to the CSR risk checker from the MVO Netherlands.

1.4.   Our CR Strategy

Village Heating has combined all its sustainability activities into one strategic programme. Under the name SEEDS, binding, quantifiable targets have been set in the following fields of focus: Environment, Employees, Development & Solutions and Society. We develop specific measures based on these targets and continuously monitor the results. Transparently and group-wide.

We manage our sustainability performance using an established approach: the classic control circle applied to corporate management systems. On the basis of the sustainability strategy, binding and verifiable targets are set for all four fields of focus in the SEEDS programme. For example supporting SOS Children’s Villages worldwide. In order to meet these targets we then implement operational measures in all relevant areas of the company. In order to test how effective these measures are, key performance indicators (KPIs) and a target figure are established for our tar- gets. Every quarter, we survey all relevant data on a group-wide basis to calculate the individual KPIs. These are brought together in a central control tool, the Vaillant Group Sustainability Score- card. By comparing figures from the same period in the previous year against the long-term tar- gets during the annual review, we are able to gain an accurate picture of the current state of our sustainability performance.

1.5.   Our Commitment To The Observance Of Human Rights

The human rights policy statement is an important part of our social responsibility.

The policy statement provides details on the observance of human rights, specifying

  • the international standards and guidelines we use as guidance,
  • the issues and areas of activity that are particularly relevant to us, g. rejecting all forms of de- grading treatment, slavery, torture, child labour or discrimination, while respecting the right of every individual to life, liberty and (social) security,
  • which measures we have implemented to ensure the observance of human rights, for example in relation to our suppliers,
  • responsibilities at the management level,
  • the opportunity for everyone to flag up grievances through a whistle-blowing

1.6.   Our Supply Chains

Our suppliers from various countries help us providing the quality our customers and business partners expect. We source a wide range of products and services from across the globe from small family-run business to large multinationals, all with their own supply chains.

As we expect our suppliers to meet our high standards, we are in constant exchange with them and seek for common understanding and united action.

1.7.   Our Measures Taken To Address Modern Slavery

A robust governance, clear policies, an effective risk assessment as well as a profound under- standing of our supply chain are basis for a targeted approach to addressing slavery and human trafficking. At Village Heating we incorporate mechanisms to preventing modern slavery at various stages: when selecting a supplier, when engaging with suppliers, when assessing them and when aiming for further development.

  • Selection process

For new suppliers we have integrated social and environmental aspects in our supplier pre-assessment. It includes:

  • A commitment to the United Nations Global Compact
  • Compliance with Minimum Wage legislation

This helps us to carefully select suppliers supporting the values Vaillant Group stands for. Furthermore, it is expected that the supplier ensures compliance with the same diligence and regulations under which he operates for Village Heating from all its sub-suppliers.

  • Key suppliers

Because of their degree of integration, the nature of their products and services or volume certain business partners play a key role in our company’s success. We are closely engaged with these key suppliers to reassure their commitment to the principles of the UNGC.

As a result, we have introduced our Supplier Quality Guideline in 2012 (updated in 2016) covering not only product and process related quality aspects but also environmental and social concerns, such as UN Global Compact.

  • Supplier Code of Conduct

In 2020 we have implemented a Supplier Code of Conduct which lays out our expectations and requirements towards our Suppliers with regards to health and safety, environment, labor, human rights and compliance.

We expect our larger suppliers to sign our Supplier Code of Conduct. This also contains requirements on forced, bonded (including dept bondage) or indentured labor, slavery and human trafficking as well as torture and degrading treatment.

  • Supplier Audits

All new suppliers are subject to a risk-oriented supplier audit covering quality, compliance, environmental and social concerns. In addition, we conduct audits of existing suppliers based on a priority matrix covering the same matters.

We developed a standardized questionnaire used in the supplier audits which includes sections on human rights and labor standards, occupational health, environmental protection and the fight against corruption.

The audit touches “labor and ethics” issues including

  • Forced labor
  • Child labor
  • Discrimination based on race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status
  • Freedom of association
  • Health and safety
  • Corruption and bribery
  • Protection of intellectual property

In case necessary, corrective action plans are agreed on which will be subject to review during the next audit at the latest. In addition, in case of a violation of the 10 principles of the UN Global Compact, the auditor is entitled to conclude the audit result as “not capable”. Depending on the seriousness of the violation the supplier might be blocked.

In 2020 we have completed roughly 154 supplier audits. Our continuous efforts ensure that within the last 4 years we have covered around 705 suppliers. Due to the Covid-19 pandemic and the travel restrictions linked to it, several audits were conducted online.

  • Training

To keep awareness high and ensure that measures preventing modern slavery are part of day-to- day business we have included respective aspects in our development efforts for suppliers and auditors.

  • Auditors receive initial training on the United Nations Global Compact, how to address this during the on-site visit.
  • Suppliers are supported by our Supplier Quality Guideline and are invited to seek for sup- port in case needed.

1.8.   Grievance Mechanism

Village Heating has implemented a grievance mechanism. Employees and third parties such as customers or suppliers can use the system to flag up grievances or report violations of laws or internal regulations without any risks being posed to the person submitting the report. The types of misconduct referred to include white-collar crimes (e.g. corruption, theft, embezzlement, money

laundering) as well as breaches of antitrust law or data privacy and violations of human rights / labor law.

Reports can also be submitted on an anonymous basis.

1.9.   Evaluation Of The Effectiveness Of Our Measures

As part of our structured approach, we review the measures taken and – in case it is necessary – redirect our efforts. At Village Heating we rely on:

  • Expert judgment (e.g. from our agents, regional experts)
  • Stakeholder dialogue (e.g. with industry associations)
  • Benchmark (e.g. to adopt best practice)

1.10.   Forward Looking Statement

Village Heating  has taken various effective measures to address modern slavery and human trafficking. In an attitude of continuous improvement, we remain committed to further strengthen our efforts in the upcoming years. We are determined to even better understand our suppliers’ activities to combat modern slavery. We will provide an update on our activities in future statements.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2021.

Daniel Dwyer

Operations Director

David Kelly

Managing Director