Kaba Ltd - Modern Slavery Act

This statement is made pursuant to Section 54, Part 6 of the UK Modern Slavery Act 2015 and sets out the steps dormakaba has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.

As part of the dormakaba group, dormakaba is fully committed to uphold the principles of and adherence to our group policies covering human rights, forced, compulsory or child labour, environmental responsibility and business ethics.

Due to the complexity of our supply chain it is challenging for us to meet all our targets in the short term. It is within our suppliers’ own responsibility to take all necessary steps to eradicate slavery and human trafficking in their own businesses and supply chains. Nevertheless, dormakaba will continue to update its policies and procedures as required to ensure that slavery and human trafficking is not taking place in our supply chain or in any part of our business.

Our core values and principles are defined in our dormakaba Code of Conduct (see Attachment I). Our dormakaba Code of Conduct serves as a rule for ethical behavior in our daily business. The dormakaba Code of Conduct contains rules and requirements regarding human rights, forced, compulsory or child labour and Compliance with all applicable law and legal regulations in the following sections:

I. Section C1: Compliance with the law and internal regulations
II. Section C2: Human Rights
III. Section C3: Trust, respect and tolerance
IIII. Section C12: Supplier code of conduct.

Our group supplier code of conduct (see Attachment 2) has recently been developed and in the UK and Ireland our centralised purchasing department will use this to further develop its processes in the selection of suppliers along with our supplier appraisals processes. Our supplier code of conduct includes three main sections of specific relevance namely:

Section I: Human rights
Section II: Fair Labour Conditions
Section III: Procurement by Supplier.

Furthermore, our internal business processes are subject to rigorous yearly internal audits by fully trained internal auditors as a result of our ISO management systems, which themselves are regularly audited for compliance by external 3rd party auditors. We also have access to group resources to aid us in the auditing of our suppliers should we require it.

Finally, it is our belief in dormakaba UK and Ireland that sustainable supply chains are ones which ensure the wellbeing of the people and environments we operate in, while seeking to grow our business and develop efficient supply chains through ethical and legal business practices.