Modern Slavery and Human Trafficking Policy

Part 1 Purpose and scope

1.1 Purpose

Modern slavery is a crime and a violation of fundamental human rights. This policy sets out how Interfloor Group Limited prevents modern slavery in its own operations and in its supply chains, how concerns are raised and handled, and how the affected person is protected.

It also provides the internal framework from which our annual statement under section 54 of the Modern Slavery Act 2015 is prepared. The statement reports what we did. This policy sets the standard we hold ourselves to.

1.2 Scope

This policy applies to:

• all Interfloor Group Limited sites and operations in the United Kingdom and the European Union. European operations are not themselves subject to the Act but are within the scope of this policy and held to the same standard;
• all employees, officers and directors, whether permanent, fixed term or part time;
• contractors, consultants, secondees and any other person performing work for or on behalf of Interfloor;
• all suppliers of goods and services, and their own sub-contractors and suppliers, addressed in Part 5.

1.3 Legal framework

This policy is written to comply with the Modern Slavery Act 2015 and to align with the Home Office Transparency in Supply Chains statutory guidance, the ETI Base Code, the UN Guiding Principles on Business and Human Rights and the relevant International Labour Organization conventions.

1.4 Relationship to Victoria PLC group documents

Interfloor Group Limited is a UK subsidiary of Victoria PLC. Victoria publishes an annual group slavery and human trafficking statement covering itself and its UK subsidiaries. Interfloor falls within its scope. Victoria is extending a group whistleblowing platform across its regions, currently operating in the United States and Australia. It is not yet available to Interfloor, so the routes at Part 7 are the operative ones.

Victoria PLC maintains a group Anti Modern Slavery Policy, identified as a key group standard in its published corporate governance statement. This policy implements that group policy at Interfloor level and does not replace it. Where this policy and a group document differ, the group document takes precedence.

1.5 Policy statement

Interfloor Group Limited has a zero-tolerance approach to modern slavery. We will not knowingly use or permit forced labour, unlawful child labour or human trafficking in any part of our business, and we will not accept goods or services from any supplier that does. We expect the same standard from every organisation we trade with.

Part 2 Definitions

For the purposes of this policy the following definitions apply.

Part 3 Roles and responsibilities

Failure by an employee to comply with this policy may be treated as a disciplinary matter. Failure by a supplier may result in corrective action, suspension or termination in accordance with Part 8.

Part 4 Requirements in our own operations

4.1 Recruitment and employment

1. Every new starter is subject to a right to work check completed before employment begins, with evidence retained.
2. Age is verified for every new starter. No person below the applicable minimum age will be employed, and no person under 18 will be assigned to prohibited or hazardous work.
3. Every worker receives a written contract of employment setting out terms, hours and pay, in a language they understand. Where a worker’s English is limited, translation or interpretation is arranged.
4. No worker shall pay any fee, deposit or deduction in order to obtain or retain work with Interfloor. Where a recruitment intermediary is used, the cost is borne by Interfloor.
5. Original identity documents are never retained by Interfloor. Copies are taken and originals returned immediately.
6. Pay meets or exceeds the applicable statutory minimum for the worker’s age band and is paid directly to an account in the worker’s own name.
7. Working hours comply with the Working Time Regulations. Overtime is voluntary and paid at the applicable rate.
8. Workers are free to leave employment on reasonable notice and free to join or not join a trade union.

4.2 Bank account verification and payroll screening

These controls exist because they detect indicators that an individual worker is unlikely to report, and in some cases cannot report.

At right to work stage

1. The account into which wages will be paid is checked against the identity documents verified for the employee. The account must be in the employee’s own name.
2. Any proposal to pay wages into an account not held in the employee’s sole name is an exception. It requires verification of the account holder’s identity and documentary evidence of the relationship, and approval by Human Resources.

During employment

1. Any change to bank details is re-verified against the employee’s identity before the change takes effect. A change part way through employment is a stronger indicator than a mismatch at hire, because exploitation frequently begins after a worker is engaged.
2. Approved exceptions are recorded on an exception register held by Human Resources and reviewed at least annually. Verifying a relationship once does not make it a standing arrangement, and financial control by another person can develop over time.

Annual screening

Account name matching does not detect every pattern. Where a worker is controlled, an account is often opened in that worker’s own name and the card retained by another person, so every name matches correctly. The following are screened at least annually:

• duplicate residential addresses across unrelated employees, which may indicate controlled accommodation;
• duplicate contact or emergency contact numbers across unrelated employees;
• clustering of accounts at an unusual branch or in sequence, which can indicate accounts opened as a group;
• a third party consistently communicating on a worker’s behalf or accompanying them to interviews and meetings.

A match is not proof of exploitation. It is a trigger for a discreet enquiry under Part 8, not for confronting the worker or their suspected controller, and not for any change to the worker’s employment.

4.3 Agency and temporary labour

Interfloor uses no labour providers, employment agencies or temporary workers. The entire workforce is employed directly. Human Resources reviews and confirms this position monthly, including at seasonal peaks.

The position has been confirmed for our European sites as well as the United Kingdom. It must be re-confirmed for each site rather than assumed to follow the United Kingdom, since agency engagement is common practice in continental manufacturing. Should agency or temporary labour be used at any site, the controls in this Part must be extended to the provider before any worker is engaged, the provider must accept the Supplier Charter, and this policy must be reviewed.

4.4 Contractors working on our sites

• Contractors are approved before mobilisation and must accept the Supplier Charter.
• Site induction includes the indicators of modern slavery and the routes for raising a concern.
• Sign-in records are checked so that the people on site are the people the contractor said would be on site.
• Cleaning, security, catering, waste and construction services are treated as higher risk and are subject to enhanced checks under Part 6.

Part 5 Supply chain requirements

5.1 Supplier Charter

Every supplier is required to commit that it will:

• not use forced or compulsory labour, being any work or service performed involuntarily under threat of penalty;
• 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;
• pay wages and benefits that meet or exceed the legally required minimum and comply with overtime pay requirements;
• comply with 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’ identity or travel documents;
• not engage in slavery, servitude, forced or 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 workers with access to a grievance mechanism free from retaliation;
• ensure that its own sub-contractors and suppliers adhere to these requirements.

5.2 Onboarding and contractual controls

1. New suppliers are risk screened before approval, using country risk, category risk and spend.
2. Any new supplier, or any new production site of an existing supplier, located in a country carrying a recognised elevated forced labour risk triggers enhanced screening before approval. On our current supply base this applies to sourcing from China and from Asia more widely.
3. Where we buy through a distributor, screening must reach the producing site and not stop at the distributor. If the producing site cannot be identified, that fact is recorded and the supplier is treated as higher risk.
4. Suppliers assessed as higher risk complete a self-assessment questionnaire before approval.
5. Purchasing terms shall include a modern slavery clause, an obligation on the supplier to notify us of any incident, a right to audit and a right to terminate for persistent non-compliance. These commitments are already carried in the Supplier Charter, which every supplier signs as a condition of trading. Replicating them in our standard purchasing terms is under review by the Purchasing Manager for introduction by 31 December 2026, at which point this requirement takes effect in both instruments.
6. Strategic suppliers are required to maintain a SEDEX membership and a valid SMETA audit.

5.3 Ongoing monitoring

• SEDEX data and SMETA audit reports are reviewed for labour standards non-conformances, and corrective action plans are tracked to closure rather than treated as closed on audit completion.
• Supplier performance reviews for strategic and key suppliers include ethical trade as a standing agenda item.
• Category risk assessments are refreshed at least annually under Part 6.

5.4 Leverage and collaboration

Where our spend is too small to compel change on its own, we will seek leverage through industry bodies, SEDEX and joint action with customers and peers.

Part 6 Risk assessment

6.1 Method

Modern slavery risk is assessed at category level and reviewed at least annually. The assessment considers:

• country risk, drawn from recognised external indices and published sector guidance;
• sector and process risk, with particular attention to labour intensive, low skill, low margin, seasonal or heavily sub-contracted work;
• workforce vulnerability, including migrant labour, language barriers, insecure status and reliance on third party accommodation or transport;
• supply chain depth and the number of tiers between us and the worker;
• our leverage, meaning the realistic ability of Interfloor to influence the supplier’s practice.

6.2 Scoring

Each category is scored for severity of harm to workers and for likelihood. Severity is assessed from the worker’s perspective and is never traded off against commercial impact on Interfloor. Categories scoring highest are designated salient risks and receive a documented action plan with a named owner and a target date.

6.3 Standing higher risk categories

The following are treated as higher risk unless assessment demonstrates otherwise. The list reflects our verified sourcing position and is reviewed annually:

• goods for resale bought finished through distributors from China, where we hold no direct relationship with the producing site. This is our largest single exposure;
• reclaimed foam collection, sorting and baling operations across the UK and EU below tier one, which are labour intensive, low margin and frequently sub-contracted;
• packaging sourced from China, where purchasing is commodity and price-led. Rubber inputs are manufactured in Asia but are synthetic rather than natural, which removes plantation-level risk, and are contracted through a major international chemicals group with a tier one relationship;
• UK road haulage, container freight and sub-contracted transport, including owner-driver arrangements;
• on-site contracted cleaning, security, catering and waste services at all sites, including those in the European Union;
• construction and project contractors engaged for capital works;
• any supplier newly sourced from a country with a recognised elevated forced labour risk.

6.4 Absence of findings

A nil return is not evidence of assurance. Where a category consistently returns no findings, the assessment shall consider whether the detection method is capable of finding what it is looking for and shall record that consideration.

Part 7 Raising and reporting concerns

7.1 Duty to report

Anyone who suspects that modern slavery is occurring, whether in our business, on our sites or in our supply chain, must report it. A suspicion is enough. It is not for the person reporting to establish whether an offence has been committed.

7.2 Reporting routes

7.3 Protection for the person reporting

No one will suffer detriment for raising a concern in good faith, whether or not the concern is later substantiated. Reports may be made anonymously, although this can limit our ability to investigate. Deliberately false reports made in bad faith will be treated as a disciplinary matter.

7.4 What not to do

• Do not confront a suspected controller, gangmaster or trafficker.
• Do not question a potential victim about their status in a way that could place them at risk.
• Do not promise a potential victim an outcome that cannot be guaranteed.
• Do not delay a report in order to gather more evidence.

Part 8 Response, investigation and remediation

8.1 Immediate response

1. Ensure the immediate safety of the person. If there is a risk to life, call 999.
2. Notify the senior compliance officer without delay.
3. Record the facts as observed, factually and without interpretation. Do not investigate unilaterally.
4. Preserve any relevant records, including sign-in sheets, payroll data and correspondence.
5. The senior compliance officer notifies the Interfloor Board without delay.
6. Where the matter may engage the group statement or another group company, the senior compliance officer notifies the Victoria PLC group company secretary.

8.2 Investigation

Investigation is led by the senior compliance officer, working with Human Resources and, where the concern relates to a supplier, with Procurement. Where a criminal offence may have occurred, the police lead and Interfloor supports. We will not run an internal investigation in a way that prejudices a police enquiry.

8.3 Remediation, and the order it happens in

Victoria PLC commits that the group will act promptly and effectively in the best interests of affected workers. This section sets out how Interfloor delivers that commitment.

Our first duty is to the affected worker, not to the commercial relationship. Remediation is considered in this order:

1. Safety and immediate needs of the affected person, including referral to specialist support and the National Referral Mechanism where appropriate.
2. Restitution, which may include unpaid wages, reimbursement of recruitment fees, and compensation.
3. Correction of the conditions that allowed the harm, through a time-bound corrective action plan.
4. Only then, a decision on the future of the commercial relationship.

Immediate termination of a supplier is not our default response. Cutting a supplier without warning can remove a victim’s income, destroy the evidence trail and push the practice out of sight. We will continue to trade with a supplier that engages genuinely with a corrective action plan, and we will exit one that does not, or one that is complicit.

8.4 Record and learning

Every reported concern, substantiated or not, is logged in the modern slavery concerns register held by HR. The register is reviewed at least annually to identify patterns, and outcomes inform the next risk assessment and the annual statement.

Part 9 Training and awareness

9.1 Role based training

Training is targeted rather than uniform. The people most likely to see an indicator are not the people who make sourcing decisions, and they need different content.

9.2  Scope of training

Interfloor Group trains to line manager level, consistent with the Victoria PLC group standard that personnel are trained to managerial level. Supervisors and other employees receive awareness training at induction.

The scope and frequency of training are reviewed annually by the document owner as part of the review of this Part. Any extension of refresher training below line manager level is a matter for the Board.

9.3 Effectiveness

Completion rates alone do not demonstrate effectiveness. We will also assess whether staff can identify indicators and state a reporting route when asked, sampled at least annually. Results inform the annual review of training content.

Part 10 Monitoring, review and the annual statement

10.1 Monitoring

Performance is monitored against the indicators published in our annual section 54 statement. Progress is reported to the senior management team and the Board at least annually.

10.2 Internal audit

Compliance with this policy is audited at least annually as part of the internal audit programme. The audit covers recruitment records, payroll screening, supplier onboarding, Supplier Charter coverage, training completion and the concerns register.

10.3 Annual statement

The statutory duty under section 54 is discharged through the Victoria PLC group statement. Interfloor additionally prepares its own statement for each financial year to provide site level detail to customers and employees. The Interfloor financial year is coterminous with that of Victoria PLC and ended on 28 March 2026. The Interfloor statement:

1. covers the six reporting areas set out in section 54(5);
2. is approved by the Board of Directors and signed by a director;
3. is published within six months of the financial year end, in a prominent place on the Interfloor website with a link from the homepage;
4. is submitted to the UK government Modern Slavery Statement Registry;
5. remains published alongside statements for previous years so that progress can be tracked;
6. is consistent with, and cross-refers to, the current Victoria PLC group statement, which is linked from the same page.

10.4 Review of this policy

This policy is reviewed annually by the document owner and on any material change to the business, the supply base or the legal framework. Changes are approved by the Board.

Appendix A Indicators of modern slavery

No single indicator proves exploitation. A cluster of indicators justifies a discreet enquiry.

Appearance and behaviour

• Signs of physical or psychological abuse, malnourishment or untreated injury.
• Withdrawn, fearful or unwilling to speak, particularly in the presence of a specific other person.
• Allowing another person to speak on their behalf, including at interview.
• Unfamiliar with the local area, or unable to say where they live.
• Wearing unsuitable clothing for the work or the weather, or the same clothing every day.

Employment and pay

• Two or more workers sharing a bank account, or wages paid into an account in another name.
• Two or more unrelated workers registered at the same address.
• A third party collecting or controlling wages.
• Reluctance to accept a pay rise, additional hours or a promotion.
• Excessive hours, no breaks, or working when visibly unwell.
• Identity documents held by someone else.

Transport and accommodation

• Groups of workers dropped off and collected by the same vehicle and driver.
• Overcrowded or unsuitable accommodation arranged by an employer or intermediary.
• Accommodation or transport charges deducted from pay at unclear rates.

In the supply chain

• Refusal of audit access, or advance notice always required.
• Workforce numbers inconsistent with output or with the site’s capacity.
• Records that appear rehearsed, identical or freshly created.
• Use of unlicensed labour providers where a licence is required.
• Prices persistently below the level at which lawful labour costs could be met.

Appendix B First response summary

This page may be displayed at site notice boards and in the personnel office.