Company Ethical Trading Policy

Applies to Interfloor Group Limited and all Interfloor Group companies

Part 1  Purpose, scope and standard

1.1  Purpose

Interfloor Group Limited recognises that its commercial activities affect a wide range of people: those it employs, those employed by its suppliers, its customers and the communities around its sites. This policy sets out the ethical standard we hold ourselves to and require of our suppliers.

We aim to operate above the minimum required by law, not merely to meet it.

1.2  Scope

This policy applies across the Interfloor Group, being Interfloor Group Limited and all companies within the Group, at all sites in the United Kingdom and the European Union. It covers:

• all employees, officers and directors, whether permanent, fixed term or part time;
• contractors, consultants, secondees, and any staff supplied by a contractor or employment agency to work on our premises or on our behalf;
• all suppliers of goods and services, and their own sub-contractors and suppliers, to the extent set out in Part 4.

1.3  Group minimum standard and local law

This policy sets a single minimum standard for the whole Group. It does not override national law.

Where national law, a collective agreement or a binding local requirement imposes a higher standard than this policy, the higher standard applies. Where it imposes a lower standard, or is silent, this policy applies. Where a provision of this policy could not lawfully be applied in a particular country, the local requirement prevails and the difference must be reported to the Risk and Compliance Manager and recorded.

Provisions that depend on national law are identified in Appendix A rather than stated as Group-wide facts.

1.4  Standard adopted

This policy is built on the Ethical Trading Initiative (ETI) Base Code and the underlying International Labour Organization conventions. We implement the principles of the ETI Base Code in full. We are not currently members of the Ethical Trading Initiative.

We also align with the United Nations Guiding Principles on Business and Human Rights.

1.5  Relationship to other documents

This policy is the parent ethical trading document for the Group. The following sit beneath it:

Modern slavery is dealt with in A15-A and is not repeated here. Where this policy refers to forced labour, trafficking or child exploitation, the definitions, procedures and remediation approach in A15-A apply.

Victoria PLC maintains a group Anti Modern Slavery Policy and group standards including the Employee Code of Conduct and the Bribery Policy. Where a Victoria PLC group document and this policy differ, the group document takes precedence and the difference must be reported to the Risk and Compliance Manager for resolution.

Part 2  Our ethical trading commitments

We trade according to the following criteria, and we ask our suppliers to affirm that their businesses are built on the same basis.

2.1  What our stakeholders can expect

• That products manufactured by the Interfloor Group are produced under conditions that are safe and hygienic.
• That all workers involved in delivering our products and services are treated with full regard to their basic human rights.
• That the Group acts ethically, above and beyond basic legal requirements.
• That we monitor social standards in our supply chain so far as we are able, and are open about where our visibility is incomplete.

Part 3  Code of practice: our own operations

3.1  No forced, bonded or involuntary labour

• All employment with the Interfloor Group is freely chosen.
• Workers are not required to lodge deposits, recruitment fees or original identity documents with us. Copies of documents may be taken and retained where required by law; originals are returned immediately.
• No worker shall pay any fee, deposit or deduction in order to obtain or retain work with us. Where a recruitment intermediary is used, the cost is borne by the Group.
• Workers are free to leave employment after reasonable notice.

Detailed controls, including verification of identity against bank account details, are set out in A15-A Part 4.

3.2  Child labour and young workers

• There shall be no recruitment of child labour anywhere in the Group or its supply chain.
• No person under 16 is employed at any time, day or night.
• No person under 18 is employed on a full-time basis.

Young workers aged 16 to 18 may be engaged in an apprenticeship, traineeship, work experience or similar structured programme where this is lawful in the country concerned and where all of the following apply:

• a specific risk assessment has been completed for the individual before work begins, addressing their inexperience and lack of awareness of risk;
• the work is not night work and does not involve prohibited processes, substances or equipment;
• working time limits for young workers under the applicable national law are observed;
• supervision arrangements are named, and the programme does not interfere with the young person’s education.

The purpose of this provision is to permit genuine training and development, not to create a route to lower-cost labour.

3.3  Freedom of association and collective bargaining

• Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
• We adopt an open attitude towards the activities of trade unions and their organisational activities.
• Worker representatives are not discriminated against and have access to carry out their functions in the workplace.
• Where local law requires or provides for a works council or equivalent body, we support its establishment and operation.
• Where the right to freedom of association and collective bargaining is restricted under law, we facilitate, and do not hinder, the development of parallel means for independent and free association and bargaining.

[CHECK FOR CEO: confirm whether any Interfloor Group site is covered by a collective agreement, and whether the Netherlands operation has a works council. Amend or delete this note before issue.]

3.4  Safe and hygienic working conditions

• We take significant measures, including investment and training, to prevent accidents and minimise hazards.
• Workers receive regular health and safety training appropriate to their role.
• Workers have unrestricted access to toilet facilities and drinking water.
• A published Health and Safety Policy is maintained and applies across the Group.

3.5  Working hours, pay and regular employment

• Pay rates are at or above the applicable national legal minimum, and are reviewed annually.
• Working hours comply with the applicable national law. The Group standard is that no worker is required to work in excess of 48 hours per week averaged over the applicable reference period. See Appendix A on national variation.
• Workers are provided with rest days in accordance with national law and the Group standard set out in Appendix A.
• Workers are given written terms and conditions setting out the employment relationship and the obligations of both parties, including rates of pay, working hours, grievance and disciplinary procedures, holiday entitlement, absence and sick pay rules, and notice periods. These are provided in a language the worker understands.
• No deductions are made from wages as a disciplinary measure. Payslips detailing lawful deductions are provided each pay period.
• Wages are paid directly into an account in the worker’s own name. Any exception is subject to the controls at A15-A Part 4.
• Labour-only contracting, sub-contracting and fixed-term contracts are not used as a means of avoiding obligations under labour or social security law.

3.6  No discrimination

There is no discrimination in pay, hiring, compensation, access to training, promotion, termination of employment or retirement on the grounds of:

• age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race, colour, nationality or ethnic origin; religion or belief; sex; or sexual orientation;
• trade union membership or activity, political affiliation, or any other characteristic protected under applicable national law.
• Opportunities for personal and career development are equally available to all workers.

3.7  No harassment, threats, abuse or intimidation

• Physical, verbal and sexual threats, abuse, harassment, bullying and intimidation are expressly prohibited and are grounds for summary dismissal if proven.
• No harsh, cruel, degrading or inhumane treatment or disciplinary practice is permitted.

3.8  Bribery and corruption

• Bribery, corruption, facilitation payments and blackmail are prohibited in every jurisdiction in which the Group operates.
• The Group complies with the Bribery Act 2010 and equivalent national legislation, and with the Victoria PLC group Bribery Policy.

3.9  Employment agencies and labour providers

The Interfloor Group does not currently use employment agencies, labour providers or temporary workers at any site. The entire workforce is employed directly. This position is reviewed and confirmed by Human Resources monthly and is under periodic review by the Group.

Should agency or temporary labour be engaged at any site, the following requirements apply before any worker is supplied:

• The agency shall demonstrate commitment to and application of this policy and shall accept the Supplier Charter.
• The agency shall hold any licence required for the activity in the country concerned, including a Gangmasters and Labour Abuse Authority licence where applicable in the United Kingdom.
• The agency shall verify that every worker supplied is lawfully entitled to work in the country concerned, under the applicable national regime. In the United Kingdom this means right to work checks under the Immigration, Asylum and Nationality Act 2006 and current Home Office guidance, carried out in a manner consistent with the Home Office code of practice on avoiding unlawful discrimination while preventing illegal working.
• The agency shall not charge any worker a fee for obtaining or retaining work.
• The agency shall ensure that every worker supplied understands the agency’s responsibilities under this policy, our health and safety requirements, and their own written statement of employment particulars, in English or in the worker’s own language.
• Workers supplied by an agency receive the same site induction as directly employed staff, including the content at A15-A Part 4.

Part 4  Requirements of suppliers

4.1  Supplier commitments

Every supplier is required, as a condition of trading with the Group, to commit that it will:

• not use forced, bonded, compulsory or involuntary labour, and ensure that the overall terms of employment are voluntary and that workers are free to leave;
• comply with the minimum age requirements prescribed by applicable law, and not use child labour;
• pay wages and benefits that meet or exceed the legal minimum, comply with overtime pay requirements, and observe applicable law on maximum daily and weekly working hours;
• not charge workers any fee to obtain or retain employment, and reimburse any fee found to have been charged;
• not retain workers’ original identity or travel documents;
• provide safe and hygienic working conditions, and respect freedom of association and the right to collective bargaining;
• not discriminate, and not permit harassment, abuse, degrading treatment, bribery or corruption;
• not engage in slavery, servitude, forced labour, compulsory labour or human trafficking anywhere in the world, including conduct outside the United Kingdom that would constitute an offence if it took place within it;
• provide its workers with access to a grievance mechanism free from retaliation;
• ensure that its own sub-contractors and suppliers adhere to these requirements.

4.2  Certification and audit

Suppliers certify compliance with this policy and their adherence to the relevant labour, human trafficking and slavery laws of each country in which they operate. On request they must demonstrate compliance to our reasonable satisfaction. We may carry out periodic audits and suppliers are expected to co-operate fully. Due diligence, risk assessment and audit arrangements are set out in A15-A Parts 5 and 6.

4.3  Consequences of a breach

The Group takes any breach of this policy extremely seriously.

Where a breach involves forced labour, human trafficking or child exploitation, the remediation sequence at A15-A Part 8.3 applies. Our first duty is to the affected worker: we secure their safety, involve the relevant authorities, and address restitution and the conditions that allowed the harm, before determining the commercial consequence for the supplier.

Immediate termination is not our default response, because ending a contract without warning can remove a worker’s income, destroy the evidence trail and drive the practice out of sight. We will work with a supplier that engages genuinely with a time-bound corrective action plan, and exit one that refuses an audit, fails to deliver a plan, or is complicit.

For other breaches the Group may require corrective action, suspend trading or terminate the agreement, having regard to the seriousness of the breach and its effect on the workers concerned.

Part 5  Responsibilities, reporting and review

5.1  Responsibilities

5.2  Raising a concern

Anyone who suspects a breach must report it. A suspicion is enough; it is not for the person reporting to establish whether a breach has occurred.

No one will suffer detriment for raising a concern in good faith, whether or not it is later substantiated. Deliberately false or malicious reports will be treated as a disciplinary matter. Where a concern relates to modern slavery, the procedure at A15-A Part 8 applies, including the guidance on what not to do.

5.3  Review and continual improvement

The Interfloor Group reviews this policy and the procedures beneath it at least annually, and on any material change to the business, the supply base or the applicable law. We recognise that our understanding of our supply chain is incomplete below tier one, and improving it is a stated priority in A15-B.

Appendix A  National variation

The following provisions depend on national law. The Group standard is stated first; the national position prevails where it differs.

Appendix B  Revision history