Modern Slavery Statement

Cleva Europe Limited - Modern Slavery Statement 2023

This statement is made pursuant to section 54(1) The Modern Slavery Act 2015 and sets out the steps that Cleva Europe Limited (a subsidiary of Cleva International Trading Limited) is taking to address the risk of slavery or human trafficking within its operations and supply chain.

Cleva Europe Limited is fully committed to operating responsibly, establishing, and adhering to the highest ethical standards. Cleva Europe Ltd is a member of Sedex an internationally recognised platform to support companies to continuously improve environmental, social, and governance (ESG) outcomes.

Business Structure
Cleva Europe Limited is a subsidiary of Cleva International Trading, which is located in Hong Kong, China. Cleva Europe Limited was established in 2017 and is a UK-based ecommerce retailer and distributer of vacuum cleaners and garden power equipment sold under the Cleva brands of Vacmaster® and LawnMaster®.

Cleva Europe Ltd directly import goods manufactured by the Cleva Group.
The key areas of our operation that could be affected by slavery and human trafficking are: 1) our directly hired employees, 2) the workforces of our supply chain, including: manufacturing, shipping, storage, fulfilment, and other business services, and 3) the workforces of our retailers.

Supply Chain
Cleva Europe Limited understands the importance of having an extensive and transparent supply chain and strives to ensure that its suppliers do not engage in any abusive, exploitative or illegal activities. We expect our direct suppliers to comply with environmental and social standards. We also ask them to require the same level of compliance from their suppliers.

We place particular emphasis on social aspects: Cleva International Trading is also a member of Sedex and has annual Sedex Member Ethical Trade Audits of it manufacturing sites and supply chains.

Cleva Europe Limited conducts due diligence on all suppliers, including retailers, before working with them. Suppliers are required to confirm that their business operations comply with the Modern Slavery Act. We reserve the right to terminate the contract at any time should any instances of modern slavery come to light.

Policies and Controls
Cleva Europe Limited acknowledges that there is a continuous risk of Slavery in all sectors, industries and jurisdictions, particularly in relation to raw materials sourcing and parts manufacturing.

Cleva Europe Limited remains committed to ensuring that there is no modern slavery or human trafficking in its supply chain or in any part of its business with a zero tolerance to non-compliance and has implemented enhanced measures to address Slavery.

Our policies ensure conduct of our employees and business is to the highest ethical standard, including:

1. Equal Opportunities Policy - We recognise the nine protected characteristics of the Equality Act 2010 and apply the provisions of the Act in full in all areas of our organisation.

2. Recruitment and Selection of Staff Policy – we verify that all workers have the right to work in the UK prior to employment. All employees are aware of their working hours, leave and absence entitlements and other benefits via the Employee Handbook and Contracts of Employment. As part of the onboarding process for joining Cleva Europe Limited, each employee receives essential policies and procedures for raising concerns.

3. “Whistleblowing” and Public Interest Policy – we operate a whistleblowing policy applicable to all workers that actively encourages the reporting of unethical behaviour and practices within our business or supply chain without fear of reprisals.

Recruitment
Cleva Europe Limited prohibits abuse and discrimination in its workforce and ensures that it complies with all applicable laws and regulations and conducts relevant checks to prevent Slavery in its workforce. At Cleva, the principles of equal opportunity and respect apply to all employees – regardless of their nationality, skin colour, gender, religion, sexual orientation, or physical disabilities. Diversity enriches our company and is an important competitive factor.

Audits
When we audit our suppliers, we look not only at aspects such as quality, supply availability and price, but also at compliance with our sustainability criteria. Compliance with environmental, social and economic sustainability criteria is monitored and verified several times over the course of a business relationship.

Company Adherence
In 2022:
• No incidents on Modern Slavery were reported.
• All suppliers to the business confirmed that their business operations complied with the Modern Slavery Act.
• Right to Work in the UK were completed for all workers prior to employment.

Signed for, and on behalf of, the Executive Board:

Douglas Begg
Managing Director