Modern Slavery and Human Trafficking Statement

In compliance with Section 54(1) of the Modern Slavery Act 2015, AQL International Ltd, trading as Aquavape, is issuing this statement to emphasise our steadfast commitment and comprehensive actions in eradicating modern slavery and human trafficking within our operations and supply chains. This statement encapsulates our efforts during the latest financial period.

Aquavape stands as one of the foremost providers of vaping products in the UK, catering to a diverse clientele through various channels such as retail outlets, petrol forecourts, motorway service stations, online platforms, and an extensive network of resellers, distributors, and partners across the EU.

Commitment to Prevention

Aquavape is deeply committed to preventing slavery and human trafficking across all facets of our corporate activities. Upholding stringent ethical standards is intrinsic to our company ethos, and we are resolute in ensuring the integrity of our supply chains.

Governance and Responsibility

The directors of Aquavape, in collaboration with our Human Resources department, bear the crucial responsibility of establishing and monitoring robust policies and procedures to fortify our commitment. Our vigilant oversight extends to promptly investigating any known or suspected instances of slavery or human trafficking within our sphere of influence.

Policies Supporting our Approach

Organisational Structure and Supply Chains

Aquavape operates within a structured framework overseen by our directors and Human Resources department. Our supply chains encompass various tiers of suppliers, from manufacturers to distributors, ensuring the widespread availability of our products across the UK and EU markets.

Employee Statement

Internal directives have been meticulously crafted to clearly articulate our commitment to combating modern slavery. These directives are disseminated comprehensively to all employees, including managers, agency workers, contractors, and consultants, outlining the expected actions and behaviours to facilitate the identification, prevention, and reporting of modern slavery within our business operations and supply chains.

Whistleblowing Policy

Aquavape fosters a culture of transparency and accountability, encouraging all employees, customers, and stakeholders to report any concerns related to modern slavery or human trafficking. Our robust whistleblowing policy ensures that individuals can disclose information without fear of reprisal, with detailed procedures outlined in our Employee Handbook.

Recruitment Practices

A stringent vetting process characterizes our recruitment practices, including thorough employment checks on all new recruits, encompassing verification of their right to work in the UK.

Agency Workers

We engage exclusively with reputable employment agencies for labour sourcing, meticulously scrutinising their practices before accepting workers sourced through them.

Due Diligence

When integrating new suppliers into our network, Aquavape conducts meticulous due diligence to assess the risk of modern slavery and human trafficking. This entails an exhaustive evaluation, including a review of the supplier's profile and geographical location to evaluate associated risk factors, understanding the intricacies of the supply chain, employing tools to assess labour standards and overall compliance, and regular reviews of existing suppliers with the imposition of sanctions or restrictions where a high risk of violation is identified.

Key Performance Indicators (KPIs)

Aquavape utilises key performance indicators to measure the effectiveness of our initiatives in combating modern slavery and human trafficking. These KPIs include metrics such as supplier compliance rates, incident reporting rates, and employee training participation levels.

Safeguarding Measures

Aquavape mandates all stakeholders to adhere to stringent measures aimed at safeguarding against modern slavery. We maintain a zero-tolerance stance towards modern slavery within our organisation and supply chains, with the responsibility placed on all individuals working for or on behalf of Aquavape to actively prevent, detect, and report any activities suggestive of modern slavery.

Enhancing Awareness and Training

Aquavape is unwavering in its dedication to enhancing internal awareness across all pertinent departments regarding the mandates of the Modern Slavery Act. We continuously strive to bolster our efforts in preventing modern slavery and human trafficking within our operational ambit and supply chains.

Board Approval and Annual Review

This statement has received unanimous approval from the Board of Directors of Aquavape and will undergo a comprehensive annual review to ensure its continual efficacy and alignment with our overarching commitments.

Ebrahim Kathrada, Director – Aquavape, April 2024