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ETHICS & COMPLIANCE STATEMENT

Modern Slavery & Human Trafficking | Anti-Bribery & Corruption

Financial Year Ending: [2027] | Published: [2026] | Version 1.0
DTECH Cabling Systems (UK) Limited | 86–90 Paul Street, London, EC2A 4NE | Company No. 10652546

This Ethics & Compliance Statement is published by DTECH Cabling Systems (UK) Limited, trading as DTECH®. It combines our statutory Modern Slavery and Human Trafficking Statement made pursuant to Section 54(1) of the Modern Slavery Act 2015, and our Anti-Bribery and Corruption Statement made in accordance with the Bribery Act 2010.

DTECH is committed to conducting its business with integrity, transparency, and respect for human rights. We have a zero-tolerance approach to modern slavery, human trafficking, bribery, corruption, and all other forms of unethical conduct — whether within our own organisation or anywhere in our supply chains and business relationships.

1. ABOUT OUR ORGANISATION

1.1 DTECH Cabling Systems (UK) Limited is a UK-based manufacturer and global distributor of professional cables and connectivity solutions, registered in England and Wales (Company No. 10652546), with its registered office at 86–90 Paul Street, London, EC2A 4NE.

1.2 We design, manufacture, procure, and distribute a wide range of cabling products including data and network cables, AV cables, audio and speaker cables, coaxial and satellite cables, alarm and security cables, control and automation cables, and associated connectivity accessories.

1.3 We operate B2B channels serving contractors, system integrators, resellers, and distributors across the United Kingdom and internationally across Europe, the Middle East, Asia, and beyond, as well as direct-to-consumer sales via our website at www.dtechcables.com.

1.4 All individuals working for or on behalf of DTECH are engaged on fair, transparent, and lawful terms, with verified right to work, pay at or above the National Living Wage, and freely chosen employment.

2. MODERN SLAVERY & HUMAN TRAFFICKING

This section constitutes DTECH’s Modern Slavery and Human Trafficking Statement for the financial year ending [2027], as required by Section 54(1) of the Modern Slavery Act 2015.

2.1 Our Supply Chains

2.1.1 Our supply chains are international in scope and include suppliers of raw materials such as copper conductors, PVC and LSZH compounds, shielding materials, and other cable components, as well as finished goods manufacturers, freight and logistics providers, and warehousing and fulfilment partners.

2.1.2 We source and procure goods from suppliers in the United Kingdom, the European Union, and Asia Pacific. We recognise that certain regions and sectors carry a heightened risk of modern slavery, forced labour, and child labour, and we apply proportionate scrutiny to our relationships with suppliers in those areas.

2.1.3 The principal risks we have identified include manufacturing operations in higher-risk jurisdictions, raw material extraction industries, and the use of labour subcontracting or agency workers within manufacturing facilities.

2.2 Our Zero-Tolerance Commitment

2.2.1 DTECH has a zero-tolerance approach to modern slavery, human trafficking, forced labour, child labour, debt bondage, and all other forms of exploitation — whether within our own business or our supply chains.

2.2.2 We will not knowingly engage with any supplier, contractor, agent, or business partner who is involved in or connected to such conduct. Where we identify such conduct, we will take immediate steps to investigate and, where appropriate, terminate the relationship.

2.2.3 We expect all employees, contractors, and supply chain partners to share these values and to comply fully with all applicable laws and regulations relating to modern slavery and human rights.

2.3 Due Diligence

2.3.1 Supplier vetting — all new suppliers are assessed prior to engagement, including review of their ethical trading credentials, labour standards, and compliance with applicable law. Higher-risk suppliers are subject to enhanced due diligence.

2.3.2 Contractual protections — our standard supplier agreements include representations and warranties requiring compliance with modern slavery legislation, ethical labour practices, and the right for DTECH to audit or request information relating to employment practices.

2.3.3 Ongoing monitoring — we monitor our supplier relationships on an ongoing basis and require suppliers to notify us promptly of any material change that may affect their compliance with our ethical standards.

2.3.4 Risk assessment — we conduct periodic risk assessments of our supply chains, prioritising higher-risk sectors, geographies, and commodity types.

2.3.5 Internal audits — we periodically review our own employment practices to identify any indicators of exploitation or forced labour within our own workforce.

3. ANTI-BRIBERY & CORRUPTION

This section sets out DTECH’s Anti-Bribery and Corruption Statement in accordance with the Bribery Act 2010. The Bribery Act 2010 makes it a criminal offence to offer, promise, or give a bribe, to request or accept a bribe, and to bribe a foreign public official. DTECH is committed to full compliance with the Bribery Act 2010 and all applicable anti-corruption laws.

3.1 Our Zero-Tolerance Commitment

3.1.1 DTECH has a zero-tolerance approach to bribery and corruption in all its forms. We will not offer, pay, request, or accept bribes or improper payments of any kind, whether directly or through any third party, in any jurisdiction in which we operate.

3.1.2 This prohibition applies to all employees, directors, contractors, agents, intermediaries, and any other person acting on behalf of DTECH, in all countries and in all circumstances.

3.1.3 We are committed to implementing and maintaining effective procedures proportionate to our risks, as required under the Bribery Act 2010.

3.2 Facilitation Payments

3.2.1 Facilitation payments — unofficial payments made to government officials or others to secure or expedite routine actions — are prohibited under the Bribery Act 2010 and under DTECH’s policy, regardless of where they occur or how they are described.

3.2.2 Any request for a facilitation payment must be refused and reported immediately to senior management.

3.3 Gifts, Hospitality and Expenses

3.3.1 Reasonable and proportionate gifts, hospitality, and business entertainment are a legitimate part of commercial relationships, but must never be used to improperly influence business decisions or gain an unfair advantage.

3.3.2 All gifts, hospitality, and entertainment given or received must be: reasonable in value and proportionate to the business relationship; transparent and capable of being openly acknowledged; permitted under applicable law; and not given or received at a time that could appear to be intended to influence a decision.

3.3.3 Cash gifts are never acceptable in any circumstances. Any non-compliant gift or hospitality must be refused, returned, and reported to management.

3.3.4 DTECH maintains a gifts and hospitality register. All gifts and hospitality given or received with a value above £50 must be recorded.

3.4 Third Party and Supply Chain Risk

3.4.1 DTECH conducts due diligence on all significant third parties prior to engagement, including assessment of their anti-bribery and corruption policies and controls.

3.4.2 All agents and intermediaries acting on behalf of DTECH must be subject to written agreements that include anti-bribery representations, warranties, and termination rights.

3.4.3 Supplier agreements include anti-bribery and corruption representations, and we reserve the right to terminate relationships with suppliers or partners found to be involved in bribery or corrupt conduct.

3.5 Political Contributions

3.5.1 DTECH does not make political contributions of any kind to any political party, candidate, or political organisation, whether in the United Kingdom or internationally.

4. SHARED GOVERNANCE FRAMEWORK

4.1 Policies

DTECH maintains the following policies supporting our ethics and compliance commitments:

4.1.1 Modern Slavery Policy — zero-tolerance position, indicators of exploitation, and staff responsibilities.

4.1.2 Anti-Bribery and Corruption Policy — detailed guidance on prohibited conduct, gifts and hospitality, facilitation payments, and reporting obligations.

4.1.3 Supplier Code of Conduct — ethical standards required of all supply chain partners, including modern slavery, anti-bribery, labour rights, and environmental responsibilities.

4.1.4 Whistleblowing Policy — confidential and protected reporting channel for all concerns relating to unethical conduct, modern slavery, bribery, or compliance failures.

4.1.5 Gifts and Hospitality Policy — detailed rules and thresholds governing the giving and receiving of gifts, hospitality, and entertainment.

4.1.6 Recruitment and Employment Policy — lawful, transparent, and fair recruitment and employment practices.

All policies are reviewed annually by senior management.

4.2 Training and Awareness

4.2.1 All employees receive ethics and compliance training as part of their induction and on a periodic refresh basis, covering modern slavery indicators, anti-bribery obligations, gifts and hospitality rules, and how to raise concerns.

4.2.2 Enhanced training is provided to employees in higher-risk roles including procurement, supply chain management, sales, finance, and any role involving dealings with public officials or international markets.

4.2.3 Our zero-tolerance commitments are communicated to all supply chain partners through our Supplier Code of Conduct and supplier onboarding processes.

4.3 Reporting and Whistleblowing

4.3.1 Any employee, contractor, supplier, or third party who suspects or becomes aware of any conduct involving modern slavery, bribery, corruption, or any other breach of this statement is encouraged and expected to report it immediately.

4.3.2 Reports can be made to senior management at connect@dtechcables.com or anonymously via our designated whistleblowing channel. All reports will be treated seriously, investigated promptly, and handled in confidence.

4.3.3 DTECH prohibits any form of retaliation against any person who raises a concern in good faith.

4.4 Consequences of Non-Compliance

4.4.1 Breaches of this statement are treated as serious matters. Employees found to be in breach may be subject to disciplinary action up to and including dismissal. Third parties found to be in breach may have their contracts terminated immediately.

4.4.2 Where conduct constitutes a criminal offence, DTECH will cooperate fully with relevant law enforcement and regulatory authorities.

5. KEY PERFORMANCE INDICATORS

We measure the effectiveness of our ethics and compliance programme through the following indicators:

5.1 Percentage of key suppliers who have acknowledged and agreed to our Supplier Code of Conduct.

5.2 Number of supplier due diligence assessments completed during the reporting period.

5.3 Number of employees who have completed ethics and compliance training.

5.4 Number of concerns raised via our whistleblowing channel and actions taken in response.

5.5 Number of gifts and hospitality entries recorded in the register during the reporting period.

5.6 Number of supplier relationships reviewed or terminated as a result of ethics or compliance concerns.

6. FUTURE COMMITMENTS

DTECH is committed to continuously improving our ethics and compliance programme. Our planned actions for the coming year include:

6.1 Expanding our supplier due diligence programme with particular focus on higher-risk tiers and geographies.

6.2 Implementing a formal supplier audit programme for key suppliers in higher-risk jurisdictions.

6.3 Enhancing our whistleblowing reporting mechanisms to make it easier for all stakeholders to raise concerns confidentially.

6.4 Reviewing and updating all ethics and compliance policies to reflect evolving legislation and best practice.

6.5 Increasing the frequency and depth of anti-bribery and modern slavery training for all relevant staff.

6.6 Engaging with key supply chain partners to promote adoption of equivalent ethics and compliance standards within their own operations.

7. BOARD APPROVAL & SIGN-OFF

This Ethics & Compliance Statement, including the Modern Slavery and Human Trafficking Statement required under Section 54(1) of the Modern Slavery Act 2015, has been reviewed and approved by the Board of Directors of DTECH Cabling Systems (UK) Limited. It will be reviewed, updated, and republished annually.

Signed:    _______________________________________________

Name:    _______________________________________________

Position:    Director / [TITLE], DTECH Cabling Systems (UK) Limited

Date:    _______________________________________________


© DTECH Cabling Systems (UK) Limited. All rights reserved. Registered in England & Wales. Company No. 10652546.