UK Modern Slavery Act Transparency Statement

Financial year 2019

This statement outlines the steps that Guardian is taking under Section 54 of the Modern Slavery Act 2015 (“Act”) to reasonably ensure that modern slavery is not occurring within our business and supply chains.

The Act defines modern slavery as slavery; servitude and forced or compulsory labor; and human trafficking.

Guardian is committed to conducting all business affairs lawfully and with integrity. One of our key principles is not only to strive for compliance with all laws and regulations, but also to treat people with honesty, dignity and respect. We hire people who share our values and beliefs and who are fully committed to this principle. Guardian’s compliance and ethics expectations are set out in our Code of Conduct, and apply to all officers, directors, and employees.

We rely on our suppliers sharing our values and complying with all laws at all times. We expect our business partners to treat people with dignity and respect and not to engage in practices associated with forced labor, even if not illegal in their locations. To ensure that modern slavery is not occurring within our supply chains, we make reasonable efforts to know our suppliers and their work practices, including their reputations for legal compliance and respect for human rights. We keep on acting to discontinue relationships with those suppliers and other third parties who fail to meet our high standards for lawful and ethical conduct.

In continuous efforts to ensure that modern slavery is not taking place in our supply chains Guardian has developed several new contract templates which include a statement by which Guardian suppliers certify that their business and supply chain are maintained in a lawful and socially responsible way including, among other things, that neither human trafficking nor slavery or forced labor takes place in any part of their business, and that they do not use slavery or forced labor in any of its forms, including human trafficking. That new contract templates are now used with all new suppliers to Guardian.

Besides that, Guardian Europe strategic suppliers have also provided Guardian assurances that they do not use forced labor in the course of manufacturing products for or providing services to Guardian.

In addition to these steps, Guardian offers a Compliance & Ethics Helpline which provides employees, customers, suppliers and members of the general public with a mechanism, including on an anonymous basis (where allowed by law), to report concerns about potential breaches of Guardian's Code of Conduct, a Guardian policy, or the law.

This statement refers to 2019 financial year and was approved by the Board of Directors of Guardian Guardian Industries UK Limited on September 17, 2020, Guardian Europe S.à r.l. on September 16, 2020.