INTERFLOOR LTD ETHICAL TRADING POLICY

5th August 2025

Summary Statement

At Interfloor Limited we believe strongly in ethical principles and good stewardship.  We are therefore proud to guarantee that we trade according to the following Ethical Trading Criteria, and this applies to all Interfloor operations:

1. All employment is freely chosen.
2. Freedom of association and the right to collective bargaining are respected.
3. Working conditions are safe and hygienic.
4. Child labour is not used.
5. Wages are fair and comparable to industry standard and will always exceed the minimum wage.
6. Deductions from wages as a disciplinary measure shall not be permitted.
7. Working hours are not excessive.
8. No discrimination is practised.
9. Regular employment is provided for those who are employed on a permanent contract.
10. No harsh, cruel or degrading treatment or practices are allowed.
11. No bribery, corruption, blackmailing or bullying is permitted.
12. No slavery or human trafficking is permitted.
13. Third Party Suppliers and buyers are both free to sell and buy from any number of other businesses.

We require our suppliers to confirm that their businesses are founded on the same ethical principles outlined in this policy. This confirmation may be provided through a written agreement, audit, or third-party certification, as appropriate. Interfloor has developed a comprehensive Ethical Trading Policy that sets out how we aim to continually improve our practices and provide assurance to our customers that the products and services we deliver have been ethically designed, managed, and implemented.

Our Full Ethical Trade Policy Statement

1. Policy Statement

Interfloor Limited recognises that our commercial activities have potential to impact on a range of stakeholders including our suppliers and our locality.

As a socially responsible business our suppliers, local community and customers have a right to expect:

• Products manufactured by Interfloor Limited are produced under working conditions that are hygienic and safe.
• All workers involved in the delivery of services provided by Interfloor Limited are treated with full consideration to their basic human rights.
• Interfloor Limited acts in an ethical manner above and beyond basic legal requirements.
• While not a member of the ETI, Interfloor adopts the principles of the ETI Base Code as a benchmark for ethical conduct.
• This policy sets out Interfloor Limited’s commitment to its suppliers and customers; setting out the measures we are taking to ensure that we are acting in an ethical manner.
• This policy sets out Interfloor Limited’s commitment to preventing slavery and human trafficking in our corporate activities, and to ensuring, as far as we are able, that our supply chains are free from slavery and human trafficking.

2. Interfloor Limited Commitment to its suppliers, service providers and customers:

Interfloor Limited recognises that our ethical and social performance and reputation is a key part of our long-term overall commercial success.

• Employees

Interfloor Limited is committed to ensuring that our employment practices and the enforcement of corporate regulations ensure the protection of the rights of all those who work for us.  In many areas we aim to operate above the minimum standards required by law to ensure our employees are safe, rewarded and valued.  As we expand and become larger we will be able to offer more opportunities for our staff.

• Customers

Interfloor Limited is committed to demonstrating its ethical and social responsibility credentials to enable customers to make informed choices about whose services they purchase.

• Suppliers

Interfloor Limited is committed to monitoring where possible, social standards in our supply chain, and we encourage our suppliers to operate to the same ethical standards we employ ourselves.

• Environmental Responsibility
  Interfloor Limited recognises that ethical business practices must include environmental stewardship. We are committed to minimising the environmental impact of our operations and supply chains, and to contributing to a more sustainable future.

As part of this commitment, Interfloor:

• Operates an environmental management system certified to ISO 14001.
• Incorporates circular economy principles into our product design, manufacturing, and waste management processes.
• Has adopted measurable carbon reduction targets, and regularly monitors and reports progress.
• Conducts supply chain sustainability assessments to ensure that our suppliers adhere to environmentally responsible practices.

We expect our suppliers and partners to comply with all applicable environmental laws and to actively work toward sustainable operations. Where appropriate, we encourage certification, transparency, and continuous improvement in environmental performance throughout the supply chain.

3. Interfloor Limited Ethical Trading Code of Practice

3.1  This Code of Practice applies to:

• Staff directly employed by Interfloor Limited on temporary or permanent contracts.
• Staff employed or provided by contractors or employment agencies to work on Interfloor Limited’s premises or to undertake work for or on behalf of Interfloor Limited.

3.2  No forced, bonded or involuntary labour shall be used.

• All employment with Interfloor Limited is freely chosen.
• Staff are not required to lodge deposits or identity papers with us.
• Staff are free to leave Interfloor Limited after reasonable notice.

3.3   No child labour shall be used

• There shall be no recruitment of child labour.
• Children or persons under 16 are not employed at any time, day or night.
• Children or persons under 18 are not employed full-time.
  • Freedom of association and the right to collective bargaining are respected
• Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
• The employer adopts an open attitude towards the activities of trade unions and their organisational activities.
• Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace.
• Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.
  • Working conditions are safe and hygienic
• Interfloor Limited takes significant measures, including investment and training, to prevent accidents and minimise potential hazards.
• Staff receive regular health & safety training.
• Staff have unrestricted access to toilet facilities and drinking water.
• Interfloor Limited has a published Health & Safety Policy.
  • Working hours and remuneration are reasonable and comparable to other companies in our sector and regular employment is provided
• Staff pay rates are significantly above the national legal minimum standards.
• Staff are not forced to work in excess of 48 hours per week, a voluntary opt out agreement is available for those wishing to work in excess of 48 hours per week.
• Staff are provided 2 days off per week
• Staff are given written terms and conditions of employment that details the employment relationship between and the respective obligations of the employee and employer, rates of pay, working hours, grievance and disciplinary procedures, holiday entitlement, absence and sick pay rules and notice periods for termination of employment.
• No deductions are made from wages as a disciplinary measure, and pay slips detailing lawful deductions are provided for each pay period.
• Labour only contracting, sub-contracting and fixed term contracts are not used as a means to avoid obligations under labour or social security laws.
  • No discrimination is practised
• There is no discrimination in pay, hiring, compensation, access to training, promotion, and termination of employment or retirement on the grounds of race, nationality, religion, age, disability, marital status, sexual orientation, union membership or political affiliation.
• Opportunities for personal and career development are equally available to all employees.
  • No harassment, threats, abuse or intimidation shall be practised
• Physical, verbal and sexual threats, abuse, harassment or intimidation is expressly prohibited and grounds for summary dismissal, if proven.
  • Employment Agencies
• All employment agencies must ensure that temporary staff are eligible to work in the UK in accordance with the Immigration, Asylum and Nationality Act 2006 and Home Office guidance on Right to Work checks.
• Employment agencies contracted to supply temporary staff shall ensure that all staff supplied to Interfloor Limited have sufficient command of English to understand:
• The agency’s responsibilities under this code of practice.
• Interfloor Limited Health & Safety requirements.
• Written statements of employment particulars.

Or have other measures in place to ensure that all these requirements are communicated in the employee’s native language.

• Organisation

Interfloor Limited Directors have overall responsibility for all aspects of ethical trading at work within the business.

• Looking towards further improvement

Interfloor Limited are keen to learn from others and regularly review our policy and procedures.

• The Modern Slavery Act – Anti-Slavery and Human Trafficking Policy Statement

In accordance with the Modern Slavery Act 2015, Interfloor Limited (“Interfloor”) is committed to a work environment that is free from human trafficking, forced labour and unlawful child labour (collectively “human trafficking and slavery”). It also strongly believes that it has a responsibility for promoting ethical and lawful employment practices.

Accordingly, Interfloor will not knowingly use unlawful child labour or forced labour in any of the utilities and/or other commodities, products and/or services it provides, nor will it accept commodities, products and/or services from suppliers that employ or utilize child labour or forced labour.

This statement is reviewed and published annually in accordance with Section 54 of the Modern Slavery Act 2015 and is approved by the Board.

Rationale

Human trafficking and slavery are crimes under UK and international law. These crimes exist in countries throughout the world. This policy statement thus defines Interfloor’s commitment to ensuring that human trafficking and slavery does not exist within its own business, but also provides how Interfloor will make efforts to eradicate the same from other businesses with whom it shall maintain a relationship (and especially from within its supply chain).

Interfloor has appointed its Finance Director as its senior compliance officer (its Anti- Slavery and Human Trafficking Officer) and will take appropriate steps to ensure not only its own compliance but also that these requirements are followed by its suppliers, subcontractors and/or business partners (collectively by its “Suppliers”) worldwide.

All Suppliers are therefore required to adhere to the following:

Definitions

Human Trafficking: the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.

Forced Labour: all work or service, not voluntarily performed, that is obtained from an individual under the threat of force or penalty.

Harmful Child Labour: consists of the employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral, or social development.

Requirements for Suppliers:

• Will not use forced or compulsory labour, i.e., any work or service that a worker performs involuntarily, under threat of penalty;
• Will ensure that the overall terms of employment are voluntary;
• Will comply with the minimum age requirements prescribed by applicable laws
• Will compensate its workers with wages and benefits that meet or exceed the legally required minimum and will comply with overtime pay requirements;
• Will abide by applicable law concerning the maximum hours of daily labour;
• Will not engage in any practice of slavery, servitude, forced labour, compulsory labour and/or human trafficking outside the UK which would constitute an offence if that conduct took place within the UK; and
• Will ensure that any sub-contractors or suppliers from whom they source goods and/or services for incorporation in those supplied to Interfloor, also adhere to these requirements.

Certification

Suppliers will certify compliance with this Policy and their adherence to relevant human trafficking and slavery laws in each of the relevant countries in which they operate.

Audits

Upon request, Suppliers must be able to demonstrate compliance with this Policy to the reasonable satisfaction of Interfloor. Interfloor may perform periodic audits on this Policy and Suppliers are expected to fully co-operate with any such audit.

Reporting

Any breach of this Policy (including by a Supplier) can be reported (in confidence, if required) by contacting Interfloor’s Finance Director (in his capacity as Interfloor’s Anti- Slavery and Human Trafficking Officer).

Consequences

Interfloor takes any breach of this Policy extremely seriously.

Suppliers who are found to have or be engaging in human trafficking and slavery or which refuse to co-operate with any audit to verify compliance with this Policy will be liable to have any supply agreement, arrangement or other contract with Interfloor terminated immediately, without compensation.

If a Supplier to Interfloor is found in violation of this policy, Interfloor will take prompt action which may include terminating any supply agreement, arrangement or other contract with that Supplier (as above). It shall also take such other (remedial) steps as the Anti- Slavery and Human Trafficking Officer shall determine to be necessary to address the violation and seek to prevent its reoccurrence.