Modern slavery statement
1. Policy Statement
Certikin International Limited is committed to conducting all business in a responsible, ethical, and transparent manner. We take a zero-tolerance approach to modern slavery, human trafficking, forced labour, and child labour across our operations and supply chains.
We are committed to acting with integrity and implementing effective systems and controls to safeguard against any form of modern slavery. This policy applies to all employees, directors, contractors, consultants, agents, customers, and suppliers.
2. Organisation Structure, Business and Supply Chains
Certikin International Limited
Certikin International Limited is a UK-based company and part of the Fluidra Group. The Company specialises in the development, manufacture, and distribution of swimming pool and wellness equipment. It operates globally, importing and exporting goods through an extensive network of suppliers and serving a well-established base of trade customers.
Fluidra Group
Certikin is wholly owned by Fluidra S.A., whose purpose is “We turn water into a better world” and whose mission is to “create the perfect pool and wellness experience responsibly.”
Fluidra operates under a global Code of Ethics and ESG framework, which includes a strong commitment to human rights, ethical labour practices, and the prevention of modern slavery across all its subsidiaries and supply chains.
3. Policies in Relation to Modern Slavery
We operate within the framework of the Fluidra Code of Ethics and have implemented supporting policies to ensure ethical conduct, including:
Fluidra Code of Ethics
Supplier Code of Ethics
Employee Equality and Anti-Discrimination Policy
Whistleblowing Policy (Confidential Channel)
All suppliers are required to comply with the Supplier Code of Ethics as a condition of doing business with Certikin. This includes explicit prohibitions on forced labour, human trafficking, and child labour, in line with:
The UN Global Compact
The Universal Declaration of Human Rights
International Labour Organization (ILO) standards
4. Due Diligence Processes
We have implemented a structured due diligence framework to identify, prevent, and mitigate risks of modern slavery:
Supplier Onboarding
All new suppliers are subject to an initial assessment, which includes a review of ethical standards and agreement to the Supplier Code of Ethics. Where appropriate, further due diligence may be undertaken based on risk factors such as geography, industry sector, and nature of goods supplied.
Ongoing Monitoring
Regular supplier reviews and performance monitoring
Periodic site visits to key manufacturing facilities, including overseas suppliers
Long-standing relationships with many suppliers’ support transparency and accountability
Contractual Controls
Supplier agreements include commitments to anti-slavery and ethical labour standards
Non-compliance may result in corrective actions or termination of the relationship
5. Risk Assessment and Management
We recognise that risks of modern slavery may arise in global supply chains, particularly in regions where labour standards may vary.
Key Risk Areas
Manufacturing operations in higher-risk regions, particularly parts of Asia
Labour-intensive production processes
Extended supply chains with limited visibility beyond tier-one suppliers
Risk Mitigation
Regular factory visits to assess working conditions
Working with established suppliers with proven ethical standards
Promoting transparency and long-term supplier relationships
Adherence to internationally recognised labour standards
We continually review and refine our risk assessment approach to ensure emerging risks are identified and managed effectively.
6. Effectiveness and Key Performance Indicators (KPIs)
We monitor the effectiveness of our approach through the following indicators:
The majority of employees complete mandatory Code of Ethics training annually, with completion tracked and followed up.
Regular supplier site visits conducted across key sourcing regions
No substantiated incidents of modern slavery have been reported during the reporting period.
All new suppliers required to sign the Supplier Code of Ethics prior to engagement
Where issues are identified, corrective action plans are implemented and monitored.
We are committed to strengthening our metrics and reporting capabilities over time to provide greater transparency.
7. Training and Awareness
We provide ongoing training to ensure employees understand modern slavery risks and responsibilities:
Mandatory Code of Ethics training for all employees and Board members (annually)
Ethics and compliance training included in onboarding programmes
Regular refreshers to reinforce awareness and accountability
Employees are expected to uphold our values and act in accordance with ethical business practices at all times.
8. Whistleblowing and Reporting
We encourage all employees and external stakeholders to report concerns about modern slavery or unethical practices.
Reporting channels include:
Line management or senior leadership
Compliance function
Fluidra Confidential Channel (anonymous reporting system)
All reports are treated seriously, investigated promptly, and handled confidentially.
9. Remediation and Corrective Action
If modern slavery is identified within our business or supply chain, we are committed to:
Investigating the issue promptly and thoroughly
Working with the relevant supplier or partner to implement corrective actions
Protecting affected individuals where possible
Terminating relationships where serious breaches are identified and not remedied
10. Responsibility for Implementation
Overall responsibility for this policy lies with the Compliance Department.
Day-to-day responsibility is held by:
Operations Director
Sales Director
Purchasing Manager
These roles are responsible for ensuring effective implementation, monitoring compliance, and addressing any risks identified.
11. Approval and Publication
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes Certikin International Limited’s modern slavery statement for the financial year ending 2025.
This statement has been approved by the Board of Directors.
Signed:
Neil Stephenson
Managing Director
Certikin International Limited
Date: 30.6.26
