Modern Slavery Act 2015

Zoro UK, is committed to the continuous improvement of our practices to combat slavery and human trafficking. Zoro UK team members are responsible for being aware and alert to the risks of forced labour and human trafficking in our business and our supply chain and are expected to report concerns to our management, which is expected to act upon them.

Business and Organisational Structure

Zoro UK is a company organised under the laws of England and Wales (company number 12143828), with its head office located in Leicester, England. Zoro UK is a multi-channel distributor of maintenance, repair and operations products primarily to business customers located in the United Kingdom. The ultimate parent company of Zoro UK is W.W. Grainger, Inc. (Grainger), a publicly traded U.S. corporation listed on the New York Stock Exchange with 2016 annual global sales of over $10,000,000,000. Additional information on Grainger can be found at the Investor Relations section of its website at grainger.

Our Supply Chains

Our key supply chains involve procuring a wide variety of goods and services. Our suppliers are often well established and have a history of responsible trade with Zoro UK or Grainger affiliated companies. The evaluation and selection of suppliers for Zoro UK's supply chain is based on the supplier's ability to provide goods that meet the required technical specifications as well as the need for satisfactory quality and service performance. These requirements are necessary to satisfy the movement of goods through the supply chain to fulfill the Zoro UK's own customer expectations.

Our Policy on Slavery and Human Trafficking

This anti-slavery policy reflects our commitment to acting ethically and with integrity in all of our business relationships and to implementing and enforcing effective systems and controls to help ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due Diligence Processes for Slavery and Human Trafficking

Our goal is to build long standing relationships with suppliers in the U.K. and across the globe and regularly visit those suppliers and make clear our expectations of business behavior. We expect these suppliers to have suitable anti-slavery and human trafficking policies and processes and conduct due diligence in their respective supply chains. As part of our induction program, new suppliers are required to disclose the programs and policies that are in place in their supply chain to combat slavery and human trafficking. We have a hotline available to all of our team members and any other interested parties, including our suppliers, in all countries where Zoro UK and Grainger physically does business (in both English and the local language) to encourage reporting of unethical or non-compliant behavior. Hotline details are found in our proposed standard terms and conditions of purchase with our suppliers. Subject to applicable law, calls made to the hotline are confidential and can be made anonymously.

Supplier Adherence to Our Values

We have zero tolerance for slavery and human trafficking in our business. In connection there with, we have modified our terms and conditions of purchasing to require compliance with the Modern Slavery Act 2015, and provide for the immediate termination of the agreement in the event that we become aware that the supplier engages in any behavior in violation of the Act. Zoro UK also has a compliance department that works closely with Grainger's other global operations to help ensure consistent and ongoing adherence to the company's core compliance and ethical values. As an affiliate of W.W. Grainger, Inc., Zoro UK shares in Grainger's corporate social responsibility commitment to operate with professionalism and integrity. This includes compliance with Grainger's supplier code of ethics, which has human rights, labour, environment and anti-corruption as its key components. Grainger's corporate social responsibility report can be found at Grainger CSR.

Training

All Zoro UK team members are trained on and are required to certify on an annual basis their understanding and compliance with the company's business conduct guidelines, which requires all team members to operate with the highest ethical, moral and legal standards. Zoro UK also provides additional guidance on slavery and human trafficking to its procurement professionals to improve their knowledge of issues relating to human rights and supply chain working conditions.

Our Effectiveness in Combating Slavery and Human Trafficking

Zoro UK reviews and develops its policies, procedures, systems and controls to help ensure ethical practices and effective compliance is present in all of its business operations. In addition to a review of the effectiveness of the steps we have taken to combat slavery and human trafficking in our supply chains, we plan to initiate the following further steps:

Applying a risk based approach to the review of suppliers within our supply chain and certification by them of compliance with the Modern Slavery Act 2015.

Continuing communication and personal contact with relevant team members within the purchasing organization to facilitate their understanding of, and compliance with, company expectations.

Reviewing and enhancing training available to the purchasing organisation to encourage further understanding of instances of modern slavery and human trafficking and compliance with the Modern Slavery Act 2015.

Last Updated 29th April 2020