Modern Slavery Statement

Financial Year

01 January 2025 to 31 December 2025

1. Introduction

1.1. Modern slavery is a crime and a gross violation of fundamental human rights. It can take various forms, including human trafficking, forced labour, debt bondage, child slavery, domestic servitude, and forced marriage.

1.2. At TruFrame, we are committed to preventing slavery and human trafficking in all areas of our business. We also strive to ensure that our supply chains are free from such practices.

1.3. This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and outlines the steps that we have taken, and will continue to take, to prevent modern slavery and human trafficking in our business and supply chains.

1.4. This statement applies to TruFrame Ltd and its subsidiaries.

2. Our Company

2.1. TruFrame is a leading UK manufacturer of windows and doors, primarily serving the business-to-business sectors. Our headquarters are located in Melton Mowbray, Leicestershire, and all operations are based in the United Kingdom.

2.2. We source raw materials and components from a network of domestic and international suppliers. Our workforce includes remote workers, office staff, operational staff, and trade counter staff.

3. Our Commitment

3.1. We recognise that modern slavery includes slavery, servitude, force and compulsory labour, and human trafficking.

3.2. TruFrame has a zero-tolerance approach to all forms of modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships.

4. Our Supply Chains

4.1. Our supply chains include uPVC profile, hardware, glass, packaging, tooling, PPE, machinery, plant hire, transport maintenance and equipment and outsourced factored goods providers.

4.2. We expect all suppliers, subcontractors, and business partners to uphold the same high standards that we do in preventing modern slavery. We work collaboratively with our supply chain partners to promote responsible sourcing.

5. Policies and Procedures

5.1. We have implemented the following internal policies to prevent modern slavery and support ethical conduct:

5.1.1. Anti-Slavery and Human Trafficking Policy (sets out our approach and responsibilities in identifying and addressing modern slavery risks);

5.1.2. Whistleblowing Policy (to encourage staff to report concerns confidentially without fear of retaliation);

5.1.3. Recruitment Policy (ensuring fair employment practices and prevents exploitative hiring, including checks on eligibility to work in the UK);

5.1.4. Anti-Bribery Policy (supports ethical conduct across our business and supply chains, helping to prevent corruption that can enable exploitation).

6. Due Diligence and Risk Management

6.1. We conduct due diligence on new suppliers and review existing supplier relationships to assess risk related to modern slavery. Our approach includes:

6.1.1. Risk assessments based on sector, geography, and labour practices;

6.1.2. Conducting supplier audits, where appropriate;

6.1.3. Requiring supplier declarations of compliance with the Modern Slavery Act 2015;

6.2. We maintain a risk-based approach, focusing on higher-risk areas for enhanced scrutiny and monitoring.

7. Training and Awareness

7.1. We provide training to all staff to raise awareness of modern slavery risks and empower them to identify and report concerns. Training is aligned with our policies and is regularly updated to reflect legal and industry developments.

8. Effectiveness and Performance Review

8.1. We measure the effectiveness of our efforts through:

8.1.1. Monitoring reports of concerns or incidents;

8.1.2. Annual supplier compliance reviews;

8.1.3. Monitoring staff training completion rates.

9. Forward Planning

9.1. The threat of modern slavery continues to evolve, and we remain committed to actively deepening our understanding of the issue. We will regularly review and enhance our approach to managing this risk and will provide updates on our progress in subsequent Modern Slavery Statements.

10. Statement Review

10.1. TruFrame will promote and publicise our Modern Slavery and Human Trafficking Statement as widely as possible using our website and internal communication processes.

10.2. We will review our statement on an annual basis.