Modern Slavery Policy

1. Modern Slavery Policy Statement

Dunhams Washrooms Systems Limited (DWS) has a zero-tolerance approach to modern slavery and is fully committed to preventing slavery and human trafficking within our business operations and supply chains.

We are committed to acting ethically and with integrity in all our business relationships and to implementing effective systems and controls to ensure modern slavery does not occur anywhere in our business or supply chain. This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and outlines the steps we take to identify, assess, and mitigate the risks of modern slavery and human trafficking.

All employees, suppliers, and business partners share responsibility for remaining vigilant to potential risks, however small. DWS is committed to continually reviewing and improving our policies, procedures, and practices to combat modern slavery.

2. An Overview of our business

Dunhams Washrooms Systems Limited (DWS) is a manufacturer and supplier of commercial washroom systems. Established in 1963, we specialise in the design and manufacture of bespoke washroom solutions for construction and refurbishment projects.

As part of our continued growth, we have expanded our product range to meet the evolving needs of our clients. We supply a range of sectors, including Education and Healthcare, and deliver projects throughout the United Kingdom.

DWS employs 26 people and operates from its headquarters in Norfolk. Further information can be found at www.dunhamswashrooms.com.

3. An Overview of Supply Chain

DWS sources sanitaryware and raw materials with an annual value of approximately £2,703774

During the 2025-2026 financial year, we worked with approximately 140 suppliers, the majority of whom operate in areas considered to be low risk. Our key supplier categories include:

• Raw materials
• IT software and services
• Telecommunications suppliers
• People and professional services suppliers
• Property and facilities management suppliers
• Third-party haulage and logistics providers

4. Risk Assessment, Due Diligence and Mitigation

Overall, the nature of DWS’s business means that the risk of modern slavery and human trafficking within our operations and Tier 1 supply chain is considered to be low.

Despite this assessment, we remain committed to ongoing vigilance. We regularly review our operations and supply chain to identify potential risks and assess what safeguards should be implemented to prevent modern slavery or human trafficking.

All DWS employees work within the United Kingdom and are legally entitled to do so. Right-to-work checks are carried out for all prospective employees as part of our recruitment process.

DWS is committed to the following principles:

• We will not use forced, bonded, or compulsory labour
• Employment is freely chosen and voluntary
• We will not retain passports or identity documents
• We will not charge recruitment fees to workers
• We comply with minimum age legislation
• Wages and benefits meet or exceed legal requirements
• Working hours comply with applicable laws
• Accurate records are maintained with full transparency

Any breach of this policy by a customer, supplier, contractor, employee, or business partner may result in remedial action, including termination of the business relationship and referral to relevant authorities where appropriate.

5. Policies and Whistleblowing

DWS maintains internal policies to ensure ethical and transparent business practices. All policies are reviewed regularly and communicated to staff through internal communications and toolbox talks.

Employees are encouraged to report concerns through an anonymous whistleblowing process, allowing issues to be raised confidentially and without fear of reprisal.

During the 2025-2026 financial year, no incidents of modern slavery or human trafficking were identified.

6. Continued Steps

DWS is committed to continually strengthening its understanding of its supply chains and maintaining transparency and accountability.

During the 2026-2027 financial year, we will:

• Continue training relevant staff on the Modern Slavery Act 2015
• Assess suppliers from the point of contract award and on an ongoing basis
• Review and enhance our due diligence and risk assessment processes

Statement Approval

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps taken by Dunhams Washrooms Systems Limited to prevent modern slavery and human trafficking during the 2026-2027 financial year.

Approved by the Board of Directors of Dunhams Washrooms Systems Limited.

Dated:  30/01/2026

Signed by:

Brendon Dunham, Managing Director