MODERN SLAVERY & HUMAN TRAFFICKING POLICY (STATEMENT)

Version: 1.0
Approved by: Cristina Cordón, Owner & CEO
Approval date: 1 January 2025
Next review: 1 January 2026

ITV Ice Makers, S.L. (“ITV”, “we”) is fully committed to preventing modern slavery and human trafficking across all our operations and within our global supply chain. We maintain a zero-tolerance policy toward any form of forced labour, servitude, compulsory labour, debt bondage, deceptive recruitment, or human trafficking.

This Statement is published voluntarily, aligning with the principles of the UK Modern Slavery Act 2015 and related international standards, regardless of statutory thresholds.

ITV designs, manufactures, and sells commercial and industrial ice machines from our facilities in Riba-roja de Túria (Valencia), Spain, distributing to wholesalers and distributors worldwide.

Our principal supply chain regions include Spain, Italy, Germany, France, Türkiye, Czech Republic, and China. We recognise that multi-tier supply chains can pose increased risks, and we address these through robust due diligence processes and internal controls.

• Code of Ethics & Supplier Code of Conduct: Require adherence to applicable labour laws, prohibiting forced and child labour, ensuring fair wages, lawful working hours, freedom of movement and association, non-discrimination, and safe working environments.

• Whistleblowing / Speak-Up Channel (Canal de Denuncias): A confidential channel for employees, contractors, and third parties to report concerns anonymously (where permitted by law). All reports are promptly investigated with a strict non-retaliation policy.

• Contractual Controls: Supplier contracts include clauses on anti-slavery compliance, the right to request evidence, perform audits, or terminate relationships in case of breach.
• Responsible Sourcing & Purchasing: We avoid procurement practices that could indirectly promote labour exploitation (e.g., unrealistic deadlines or unplanned lead times).

We apply a risk-based approach, prioritising enhanced checks where country, sector, or product risks are higher:

• Supplier Onboarding: Pre-qualification questionnaires covering labour practices, certifications, and sub-tier sourcing.

• Risk Screening: Evaluation based on country risk indices, industry exposure, and supplier performance.

• Verification & Audits: Requests for certifications, third-party audit reports, or on-site/remote assessments.

• Corrective Actions: Identified issues trigger remediation plans with defined timelines. Severe or unresolved breaches may lead to suspension or termination.

• Annual training for procurement, quality, and logistics teams on identifying and addressing modern slavery risks.
• Induction briefings for all new employees in relevant functions.
• Practical guides and checklists to support factory visits and supplier evaluations.

Effectiveness is monitored through the following indicators:

• Percentage of active direct suppliers who have accepted our Supplier Code of Conduct.
• Percentage of high-risk suppliers assessed or screened in the past 12 months.
• Training completion rate among targeted teams.
• Number of incidents reported and resolved through our Speak-Up Channel.

Progress and outcomes will be reported in future updates of this Statement.

Ice cube 40 gr.
39,8 mm (W) x 44 mm (H)

Ice cube 40 gr.
39,8 mm (W) x 44 mm (H)

Concerns are escalated to the Compliance Function and the Executive Team.
Where harm is identified, we prioritise the safety, protection, and remediation of affected workers, working alongside competent authorities and expert organisations in line with the UN Guiding Principles on Business and Human Rights. 

Reports may be submitted confidentially via our Speak-Up Channel (Canal de Denuncias) or directly to compliance@itv.es, or through the contact form on our corporate website.

Submissions may be made in Spanish or English. We strictly prohibit any form of retaliation against individuals who report concerns in good faith.

Signed on behalf of ITV Ice Makers, S.L.

Cristina Cordón

Owner & CEO

Suppliers and sub-suppliers must:

1. Prohibit all forms of forced, bonded, or indentured labour and human trafficking; prohibit retention of identity documents and recruitment fees.
2. Prohibit child labour and comply with minimum age and young worker protection laws.
3. Ensure fair wages, lawful working hours, and rest periods.
4. Respect freedom of movement and the right to leave employment with reasonable notice.
5. Provide safe and healthy workplaces, free from harassment, abuse, and discrimination.
6. Maintain transparent records and cooperate with reasonable audits or assessments.
7. Cascade these requirements through their own supply chains and promptly notify ITV of any material breaches.

Non-compliance may result in corrective action, suspension, or termination.