1. Our Business

PHC is an independent, family-owned distributor of plumbing, heating, renewable-energy and electrical products, supplying customers throughout the United Kingdom across the public and private sectors.

We work with housing providers, local authorities, facilities-management organisations, contractors and maintenance providers. We deliver reliable materials supply supported by technical expertise, strong customer relationships and responsible business practices.

Our reputation has been built on integrity, trust and long-term partnerships. These principles guide how we serve our customers and how we work with employees, suppliers and other business partners.

2. Our Commitment

PHC is committed to conducting business ethically, responsibly and with respect for internationally recognised human rights.

We have zero tolerance for modern slavery, human trafficking, forced or compulsory labour, servitude, child labour or any form of exploitation.

We expect the same high standards from everyone who works for, with or on behalf of PHC, including suppliers, contractors and other business partners.

Our commitment extends beyond compliance with legislation. We believe responsible business practices are fundamental to sustainable commercial success and to maintaining the confidence of our customers, employees and stakeholders.

3. Our Supply Chain

PHC sources products primarily from established manufacturers and authorised distributors located within the United Kingdom and Europe.

Wherever practicable, we procure through recognised and accountable supply routes, enabling greater product traceability, quality assurance and visibility throughout the supply chain.

Although our direct supply chain is considered relatively low risk, we recognise that modern slavery risks may exist within lower tiers of global manufacturing, raw-material sourcing, transportation and logistics.

We remain committed to maintaining appropriate oversight and continually strengthening our supplier-assurance processes.

4. Governance and Due Diligence

PHC operates a proportionate approach to identifying and managing modern slavery risks.

Our controls include:

• Supplier onboarding and approval procedures
• Risk-based supplier due diligence
• Procurement through approved suppliers
• Supplier performance monitoring
• Maintenance of product traceability where practicable
• Review of relevant supplier policies and compliance information
• Investigation of concerns raised through our reporting procedures
• Escalation of significant or unresolved concerns

Where concerns are identified, we seek to work constructively with suppliers to achieve appropriate improvements.

Where significant risks remain unresolved, PHC reserves the right to suspend or terminate the relevant commercial relationship.

5. Risk Assessment and Management

We recognise that modern slavery risks can vary according to product type, manufacturing location, labour model, supply-chain complexity and the use of subcontracted services.

Our approach is to focus attention on areas where the nature of the goods, services, location or supply route may indicate an increased risk.

Where appropriate, we may request further information from suppliers, review their policies and assurance processes, or seek confirmation of the steps they take to protect workers and manage risks within their own supply chains.

Concerns identified through due diligence, employee reports or other sources will be reviewed and escalated according to their nature and severity.

6. Human Rights

PHC supports the protection of internationally recognised human rights throughout its operations and supply chain.

We are committed to promoting workplaces where:

• Employment is freely chosen
• Discrimination, harassment and intimidation are not tolerated
• Individuals are treated fairly and with dignity
• Workers receive lawful pay and working conditions
• Health, safety and wellbeing are protected
• Equality, diversity and inclusion are respected

These principles underpin our relationships with employees, customers, suppliers and the communities in which we operate.

7. Our Employees

Employees play an important role in helping to identify and prevent modern slavery.

PHC promotes an open culture in which concerns can be raised without fear of retaliation. Employees are encouraged to report suspected unethical or unlawful practices through management or the company’s whistleblowing arrangements.

Relevant employees receive appropriate awareness and guidance to support the identification, escalation and reporting of potential concerns.

8. Measuring Effectiveness

PHC reviews the effectiveness of its approach by considering relevant information about:

• Completion of appropriate supplier due diligence
• Concerns identified through supplier reviews or internal reporting
• Corrective actions requested from suppliers and the progress of those actions
• Employee awareness activities and relevant training
• Significant changes in the nature or location of our supply chain
• Developments in legislation, guidance and recognised good practice

We will continue to develop meaningful measures as our supplier-assurance processes mature.

9. Continuous Improvement

PHC recognises that preventing modern slavery requires ongoing vigilance.

We continue to strengthen our governance arrangements through:

• Regular review of supplier due diligence
• Enhancement of supplier risk assessment
• Employee awareness and training
• Engagement with suppliers on ethical sourcing
• Monitoring changes in legislation and recognised good practice
• Annual review of this statement and associated policies

10. Approval and Sign-Off

This statement has been prepared in accordance with section 54 of the Modern Slavery Act 2015 and describes the steps taken by PHC in relation to modern slavery risks during the relevant financial year.