KOMPAN Modern Slavery Statement

Organisational structure and supply chains

This statement covers the activities of KOMPAN:

• Playground and Outdoor Fitness Equipment Suppliers and Installers.

Countries of operation and supply The organisation currently operates in the following countries:

• England, Wales, Scotland, Northern Ireland

High-risk activities

The following activities are considered to be at high risk of slavery or human trafficking:

• Construction is considered a high risk industry for modern slavery. KOMPAN works with approved suppliers and sub-contractors; our risk factor is low.

• Manufacturing is considered a high risk industry for modern slavery. KOMPAN manufacturing is based in Central Europe and our material is sourced from Europe; our risk factor is low.

Responsibility

Responsibility for the organisation's anti-slavery initiatives is as follows:

• Policies: Jan Johannesen, Group HR Director

• Investigations/due diligence: Casper Jusslin, Group Compliance Manager

• Training: Jan Johannesen, Group HR Director

Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing Policy The organisation encourages all its workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains, of the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers, or others who have concerns can [use our confidential helpline/complete our confidential disclosure form].

• Business Ethics Policy The organisation's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain. Supplier Code of Conduct The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics.

• Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the organisation's supplier code of conduct will lead to the termination of the business relationship.

• Illegal Workers Policy As an employer we have a legal responsibility to prevent illegal working in the UK. The Immigration, Asylum and Nationality Act 2006 places the requirement for all employers to conduct basic document checks on every person that they intend to employ. By undertaking document checks we can be reassured we are complying with our legal obligations and are doing everything possible to only employ people who are allowed to work in the UK.

Due diligence

KOMPAN undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation's due diligence and reviews include:

• Evaluating the modern slavery and human trafficking risks of each new supplier

• Conducting supplier audits or assessments

• Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators

The organisation has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation is

• Requiring all staff to have completed training on Business Ethics as part of on-boarding programme.

• Requiring all Suppliers to comply with KOMPAN’s Supplier Code of Conduct.

• Requiring all new Suppliers to complete KOMPAN’s Supplier PQQ.

Training

The organisation requires all staff within the organisation to complete training on modern slavery as a module within the organisation's wider Business Ethics training.

The organisation's modern slavery training covers

• Our business's purchasing practices, which influence supply chain conditions, and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline.

• How to identify the signs of slavery and human trafficking.

• What initial steps should be taken if slavery or human trafficking is suspected.

• How to escalate potential slavery or human trafficking issues to the relevant parties within the organisation.

• What external help is available, for example through the Modern Slavery Helpline, “Unseen” and "Stronger together" initiative.

• What steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation's supply chains.

Awareness-raising programme

As well as training staff, the organisation has raised awareness of modern slavery issues by putting up posters/circulating a series of emails to staff.

• The poster/emails explain to staff:

• The basic principles of the Modern Slavery Act 2015.

• What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and What external help is available, for example through the Modern Slavery Helpline.