Introduction
This statement outlines the measures undertaken by Whitecroft Lighting to identify, assess, and mitigate potential modern slavery risks within its operations and supply chains. It covers the actions and activities carried out during the financial year 1 January 2026 to 31 December 2026.
As a company operating within the manufacturing sector, we recognise our responsibility to apply a rigorous and proactive approach to preventing modern slavery and human trafficking. We continue to take this obligation extremely seriously, including in the context of ongoing global challenges affecting labour and supply chain practices.
Whitecroft Lighting remains fully committed to ensuring that slavery and human trafficking have no place within its organisational activities or supply chains, and we uphold the highest standards of ethical conduct throughout all areas of our business.
Organisational structure and supply chains
Whitecroft Lighting is one of the United Kingdom’s foremost manufacturers of commercial lighting solutions. Operating from a 10,000‑square‑metre design and manufacturing facility, the company delivers tailored lighting systems for commercial, industrial, healthcare, educational, and residential applications, primarily within the domestic market.
Our annual manufacturing capability exceeds 600,000 luminaires, supported by sustained investment in advanced technologies, including the integration of in‑house LED production. As part of the Fagerhult Group, we form part of an international network of lighting manufacturers employing more than 4,900 individuals across 30 countries worldwide.
Policies in relation to Modern Slavery
The company maintains a suite of internal policies designed to promote ethical business conduct and ensure transparency across all operations. These include:
• Social Responsibility Statement – Establishes the company’s position on modern
slavery, provides guidance to employees on recognising potential concerns, and outlines reporting mechanisms.
• Recruitment Policy – Ensures a robust and lawful recruitment process, including
mandatory right‑to‑work checks for all employees, thereby safeguarding against forced labour or human trafficking.
• Equal Opportunities and Diversity – Promotes a workplace environment free from
discrimination, harassment, victimisation, and bullying, and reinforces the principle that all individuals are entitled to dignity and respect.
• Supplier Code of Conduct – Ensures that all suppliers to Whitecroft Lighting operate at the highest ethical standards.
These policies are available for suppliers and or employees to access via our website and internal learning management system.
Supplier/Procurement Code of Conduct
Whitecroft Lighting maintains an approved supplier base comprising more than 200 suppliers, including suppliers within the Fagerhult Group located in China and Turkey.
We require all suppliers to operate to the highest ethical standards. This includes providing safe working conditions, respecting employee rights, and ensuring full legal compliance in the conduct of their operations. We work collaboratively with suppliers to help them meet these standards; however, any serious breach of our Supplier Code of Conduct may result in the immediate termination of the business relationship.
Our Anti‑Slavery Policy is embedded within all supplier contracts, obliging suppliers to confirm that their operations are consistent with our expectations and that they actively implement measures to prevent slavery and human trafficking. Throughout 2026, we will continue to enforce the requirement for suppliers to complete our Ethical Trading Questionnaire, which includes declarations regarding child labour, human trafficking, and modern slavery. Suppliers are also reminded that any confirmed instances of modern slavery may lead to the termination of contractual arrangements.
Whitecroft Lighting recognises that the greatest potential risks of modern slavery arise within manufacturing supply chains and in regions where labour standards and enforcement may vary. Our risk assessment focuses on supplier geography, labour intensity, and the use of subcontracted labour, which informs our due diligence and monitoring activities.
Due Diligence Processes
All new and existing suppliers are requested to sign our Code of Conduct with ‘enforced labour’ a key area where we expect our suppliers to constantly work to identify risks and areas of improvement. As noted, the risk identification process and the implementation of improvement actions shall be based on the OECD Due Diligence for Responsible Business Conduct.
Our due diligence includes supplier questionnaires, monitoring activities, and plans to expand mapping beyond our Tier 1 suppliers. Corrective action requirements are communicated where noncompliance is identified.
Effectiveness Measures that we track include the following:
• Percentage of suppliers completing annual assessments.
• Number of suppliers identified for enhanced due diligence.
• Issues detected and resolved.
Our Workforce and Employment Practices
In addition to the due diligence carried out with our suppliers, we are also vigilant within our own workforce to ensure that our processes and practices do not impact our employees. This includes
• Right-to-work checks and lawful recruitment
• No recruitment fees are charged to employees, and the business does not retain original identity documents; copies of documentation (such as passports) are taken where required.
• Whitecroft maintains oversight of any agency or temporary labour arrangements, including ensuring that agencies comply with legal requirements, do not charge recruitment fees, and operate in line with our ethical standards.
• All employees have the right to raise a grievance in accordance with the Grievance Policy or to whistle blow in line with the Whistleblowing Policy.
Training
Whitecroft Lighting delivers regular training to any employee where it may be relevant, such as its procurement and buying teams, to ensure they are able to recognise the indicators of modern slavery and are fully aware of the procedures to follow should a concern arise within the supply chain. This training forms an essential component of our commitment to preventing modern slavery across our business activities.
Escalation and Remediation Procedures
Reported concerns follow an internal escalation process. We require suppliers to remediate any labour non-compliance, and we support corrective action planning. Contracts may be terminated where violations persist.
Approval for this statement
This statement has been approved by the Board of Directors and signed by a designated Director of Whitecroft Lighting Limited.
©2026 Whitecroft Lighting | Company number 3848973