Modern Slavery Statement for the Financial Year 2020

The statement below covers Anixter Limited (Anixter) and its wholly owned subsidiaries, Anixter Pension Trustees Limited, Anixter Middle East FZE, Anixter Distribution Ireland Limited, Anixter Saudi Arabia Limited, HMH Pension Trustees Limited, Infast Group Limited (and its wholly owned subsidiary Haden Drysis S.A.), Anixter (U.K.) Limited, and Anixter Pension Scheme Trustees Limited (together Anixter Group).

This joint statement for the Anixter Group sets out the steps taken during the financial year ended December 31, 2020 to ensure that slavery and human trafficking is not taking place in our supply chains and our own business.

Section 1 – Organisation structure

The Anixter Group is a wholly owned subsidiary of Wesco International, Inc., a leading global distributor of communications, network & security solutions, electrical & electronic solutions and utility broadband solutions. As a global organisation, Wesco International Inc. and its affiliates1 (Wesco Group) help build, connect and protect applications and environments around the world. We promote responsible commercial practices at every level of our business and are committed to conducting our business ethically, honestly and in a lawful manner. To learn more about our business, visit /about-us/more.

The Wesco Group conducts its business in four regions, North America, Caribbean and Latin America, Asia-Pacific and Europe, Middle East and Africa. Our key suppliers are manufacturers and other distributors of communications, network & security solutions, electrical & electronic solutions and utility broadband solutions products. We endeavor to build up long-term relationships with many of our suppliers, which help us to ensure that products in our inventory have been sourced in an ethical and lawful manner.

In addition to these product vendors, we also have a number of vendors which help us to run our business, such as IT, security, legal, financial and cleaning services providers, customs brokers, freight forwarders, commission agents and others.

Consultation occurs within the Anixter Group through participation by senior leadership team members in Regional Compliance Committee meetings that are held at regular intervals and by the organisation’s internal advisors who support Anixter Group’s compliance program in consultation with relevant senior leadership for each entity. In the preparation of this statement senior leadership team members in the UK and in other parts of the world were consulted.


1 Anixter Inc. and Wesco International, Inc. were separate listed public entities on the New York Stock Exchange and merged on 22 June 2020. Integration efforts are under way and pending completion of this Anixter Inc. and its subsidiaries and Wesco International, Inc. and its subsidiaries will continue to follow and comply with its policies and procedures immediately prior to the merger. Our UK entities have published modern slavery statements in compliance with the UK Modern Slavery Act 2015. Not all of the entities that are part of the Wesco are subject to modern slavery legislation.

This statement sets out the steps taken during the financial year ended December 31, 2020 to ensure that slavery and human trafficking is not taking place in our supply chains and our own business.

Section 2 - Our Business and Supply Chains

Wesco Group conducts its business in four regions, North America, Caribbean and Latin America, Asia-Pacific and Europe, Middle East and Africa. Our key suppliers are manufacturers and distributors of communications, network & security solutions, electrical & electronic solutions and utility broadband solutions products. We endeavor to build up long-term relationships with many of our suppliers, which help us to ensure that products in our inventory have been sourced in an ethical and lawful manner.

In addition to product vendors, we also have vendors which help us to run our business, such as IT, security, legal, financial and cleaning services providers, customs brokers, freight forwarders, commission agents, advisors and other service providers.

Section 3 - Policies and Contractual Controls

Anixter Group’s commitment to ethical and socially responsible approach to doing business includes but are not limited to implementing and enforcing policies such as:

In addition, suppliers and business partners are held to high ethical standards by our expectation that they abide by our policies.

To support such programs, Anixter Group has teams of internal advisors and experts whose primary focus is on compliance and corporate responsibility, such as internal audit, trade compliance, legal, human resources, environmental, sustainability and health and safety. We will also call on external experts as needed. This support is available to every Anixter Group subsidiary. Using the combination of our programs and the support of internal experts, Anixter Group ensures its commitment to ethical and socially responsible approach to doing business at all relevant times.

In 2012, Anixter Inc. became a participant to the United Nations Global Compact, the world’s largest corporate sustainability initiative. Anixter Inc. has embraced the ten principles of the Global Compact, including principle 4 which prohibits all forms of forced and compulsory labor. You can find our Corporate Responsibility Report which describes our actions to continually improve the integration of the Global Compact and its principles into our business here.

Our position on the protection of human rights is summarized in our statement on Global Human Rights Principles: we are committed to integrating respect for human rights into our practice throughout our supply chain.

Our internal policies include the Ethics and Business Conduct Policy, which applies globally and is designed to assist us in complying with the laws and ethical principles that govern our business conduct.

In our standard supplier contracts, we require our suppliers to comply with the Supplier Code of Conduct, which among other things, prohibits forced labor and human trafficking and requires our suppliers to source products only from third parties who uphold similar standards of integrity and ethical compliance as set forth in the code.

We also operate a Business Integrity Line, where anyone may online (at Anixter.ethicspoint.com) or by telephone anonymously (where permitted by local law) report violations of our policies or the law. The Business Integrity Line is operated by an independent third party and supported by our Global Anti Retaliation Policy that ensures that the whistleblower is appropriately protected.

Section 4 - Risk Assessment and Due Diligence

Business partners that represent a greater risk are required to complete our business partner qualification process. If the business partner fails to satisfactorily complete the qualification process, they will not be paid without the prior approval of a Regional Compliance Officer.

Anixter’s business partner qualification process includes a due diligence screening of all new or renewing business partners who will be performing services for or acting on our behalf in certain higher risk countries or categories of service which we identified. High risk countries are typically identified as (A) any country with a rating of Tier 2 or more in the previous year’s Trafficking in Persons Report issued by the Department of State of the United States; or (B) any country with a Corruption Perceptions Index (CPI) score of 40 or less on the previous year’s index issued by Transparency International; or (C) recommended for screening by a Regional Compliance Officer. Our internal processes include continuous monitoring of some of our approved business partners who have been identified as higher risk.

Section 5 - Training

All Anixter employees receive training and are required to certify that they comply with the Ethics and Business Conduct Policy annually. This is in addition to targeted live training that are provided throughout the year.

Section 6 - Oversight, Effectiveness and Accountability

The effectiveness of our programs can be measured through our company wide reporting processes which are supported throughout our organisation by internal and external resources including but not limited to internal audit, vendor compliance, trade compliance, legal, human resources, environmental, sustainability and health and safety teams.

All our compliance programs, including our efforts to combat slavery and human trafficking, are overseen and enforced at the highest level in the organization. The overall Compliance Program direction is determined by the Executive Compliance Committee. At a regional level we have established Regional Compliance Committees across the globe. Our Regional Compliance Committees are chaired by a Regional Compliance Officer, each of whom sits on the Executive Compliance Committee and reports annually to the Executive Compliance Committee on ethics and compliance risks in their respective regions.

The Home Office Statutory Guidance on the Modern Slavery Act 2015 recommends 6 areas and these are addressed as follows in our statement:.

Recommended Reporting Criterion Reference
Organisation structure and supply chains. Section 1 and 2
Policies in relation to slavery and human trafficking Section 3
Due diligence processes. Sections 3, 4 and 5,
Risk Assessment and Management Sections 4
Key performance indicators to measure effectiveness of steps being taken Sections 6
Training on modern slavery and trafficking Sections 5

This statement has been approved by the Board of Directors of Anixter Limited

/s/ Babayemi Abiodun-Adeleye

Babayemi Abiodun-Adeleye
Director
Anixter Limited
Date: 30 June 2021