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Anti-Slavery & Human Trafficking Statement

Modern slavery and human trafficking statement pursuant to section 54 of the Modern Slavery Act 2015

This statement is published pursuant to section 54 of the Modern Slavery Act 2015 and is the modern slavery and human trafficking statement of Solar Illuminations Ltd.

Solar Illuminations Ltd is very much committed to acting ethically and with integrity in all of its companies' dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in its own companies or in its supply chains.

Solar Illuminations Ltd is a privately owned company, registered in England & Wales, and incorporated under the Companies Act 2006 as company number 11679199.

Solar Illuminations predominantly supplies solar lights and solar lighting systems. These supplies are made to the wholesale trade, distributors, retailers, contractors and end-users. Some of the products and systems are supplied and installed at sites within the UK. The supply chain is not complex. Most suppliers to Solar Illuminations Ltd are either UK or USA based although some parts and components are supplied from other countries in Europe and also Asia. Sometimes there can be a number of levels of suppliers between Solar Illuminations Ltd and the raw materials at the very beginning of the process. As such, respecting and complying with modern slavery, human trafficking and general human rights obligations is just as much the responsibly of our suppliers as it is of Solar Illuminations Ltd.

Risk Assessment
Solar Illuminations Ltd aims to have systems in place which:

• identify and assess potential risk areas in Solar Illuminations Ltd supply chains; mitigate the risk of slavery and human trafficking occurring in the supply chains; monitor potential risk areas in Solar Illuminations Ltd supply chains; and protect whistleblowers.

The steps set out throughout the rest of this statement are aimed at remedying and mitigating identified areas of risk. Solar Illuminations Ltd hopes that the steps it takes will eliminate the risks of modern slavery and human trafficking taking place in its own businesses and its supply chains.

Code of Conduct & Business Ethics
Solar Illuminations Ltd has published on its website, a Code of Conduct and Business Ethics which applies to all aspects of the supply of goods and services provided to Solar Illuminations Ltd. The Code of Conduct and Business Ethics is provided to potential suppliers as part of the procurement process. The Code of Conduct and Business Ethics communicates the high standards expected of all partners and suppliers.

Under the Code of Conduct and Business Ethics, a prospective supplier must, amongst other requirements:

• comply with all of the applicable laws, statutes, regulations and codes of the countries it is present in;

• maintain a safe and civilised work environment;

• uphold the human rights of all employees and adhere with all laws, regulations, codes and government guidelines on human rights;

• take all reasonable steps to ensure there is no slavery, human trafficking or child labour taking place in its supply chains or elsewhere in its business;

• keep up to date with its understanding of the Modern Slavery Act 2015 and be in compliance with its requirements at all times.

Internal Policies
Solar Illuminations Ltd has an Anti-Slavery and Human Trafficking Policy in place which all its employees must adhere to. Employees are encouraged to report any act, treatment of workers or working conditions within its business or any tier of its supply chain that they feel constitutes any of the various forms of modern slavery and human trafficking. Reports can be made to their manager, the Managing Director, or confidentially in accordance with its Whistleblowing Policy. Solar Illuminations Code of Conduct and Business Ethics applies to its own staff in addition to all its suppliers. In addition, a number of other internal policies are in place which ensure that slavery and human trafficking are not taking place in its businesses. Such internal policies include policies in respect of anti-bribery and corruption, whistleblowing, diversity and recruitment. Solar Illuminations Ltd carries out "right to work" checks on all direct employees prior to them commencing their roles in the business. This includes (but is not limited to) checking that the employee has a valid visa or employment authorisation and is of an appropriate age to work.

Due Diligence
As part of Solar Illuminations Ltd procurement process, potential suppliers are required to complete a questionnaire to be considered as part of their bid. A proportion of questions are specifically aimed at ensuring that the potential supplier is aware, at an early stage of the procurement process, of its obligations to act ethically and that Solar Illuminations Ltd will not tolerate human trafficking, modern slavery or any other unethical practices in its supply chains.

Solar Illuminations Ltd initially reviews all completed questionnaires. This is to ensure that moving forward, all potential suppliers are required to confirm that they are in full compliance with the Modern Slavery Act 2015 and with Solar Illuminations of Conduct and Business Ethics before they are fully engaged by the business.

The potential supplier's response will be assessed by the procurement team, with particular emphasis placed on answers to questions in relation to human rights and modern slavery.

Where possible, Solar Illuminations Ltd seeks to conduct audits on certain high-risk tier 1 suppliers to monitor compliance with their legal requirements and expected standards. This is in an effort to ensure that all of its suppliers work in accordance with its expectations.

Solar Illuminations Ltd always aims to use its own standard terms and conditions which includes anti-slavery and human trafficking provisions. If a supplier breaches any of these provisions, Solar Illuminations Ltd respectively, reserves the right at its discretion to terminate the contract with that supplier.

Solar Illuminations Ltd suppliers are not allowed to sub-contract with third parties without prior express written consent therefore ensuring a continuous oversight over the supply chains. Where appropriate, and with the welfare and safety of those individuals at risk as a priority, Solar Illuminations Ltd provides support and guidance to its suppliers to help them address any concerns in their businesses and supply chains.

Solar Illuminations Ltd recognises the importance of its staff being aware of and understanding the risks of slavery and human trafficking. Solar Illuminations Ltd seeks to ensure that appropriate staff are able to identify the signs of slavery and human trafficking and that such staff are aware of what action to take if such activities are identified or suspected. During the next financial year, Solar Illuminations Ltd will continue to seek to deliver training to employees in the roles it considers to be most likely to be in a position to identify and address modern slavery and human trafficking risks.

Work In Progress
Solar Illuminations Ltd is committed to eradicating the risk of slavery and human trafficking and continues to be proud of the steps taken in previous years. It is also recognized and accepted that modern slavery and human trafficking are evolving issues. Therefore, Solar Illuminations Ltd will continue to consider the effectiveness of the steps it is taking to eradicate modern slavery and human trafficking from its businesses and its supply chains and may take such further steps as it considers may be appropriate to address any risk of slavery or human trafficking.

This statement was accepted approved by the Managing Director of Solar Illuminations Ltd on 30th November, 2018.