Modern Slavery Act Statement 2024-2025

Organisational and supply chain structure

Audiotonix Limited is the main holding Group company housing many prominent brands within its portfolio. These include Allen & Heath, Audio Ltd, Calrec Audio, DiGiCo, Fourier Audio, Solid State Logic, Harrison Audio (USA), Group One (USA) Sound Devices (USA), Slate Digital (FR, USA), sonible (AT) and KLANG (DE). The group revenue is over £300M with 820+ employees across these brands, where we design and manufacture professional audio solutions for the live and recording audio industry. Our main manufacturing sites are located in the UK, with one site in the USA.

The Audiotonix group designs and manufactures Professional Audio Mixing products for Live Sound, Recording and Broadcast, and the products can be found installed in theatres, stadiums, recording studios, postproduction facilities, conference centres, cruise ships, houses of worship, and on film sets as well as on worldwide tours with renowned artists.

Our supply chain is a mixture of offshore CMS (Contract Manufacturing Services) and UK based subcontractors as well as large Industry known distributors at the component level. Our UK and US sites are a mixture of NPI (New Product Introduction), final assembly and test facilities. Our products are, in the main, distributed via independent distributors in over 90+ countries worldwide.

As shown in the heat map above, the majority of the groups spend is located in China (59%). This is predominantly with a single contract manufacturing service (CMS) provider who is providing full turnkey products that ship direct to our customers across the globe. Of the total spend in China, 76% is solely for one of our brands, with the remaining spread across the other manufacturing entities. Audiotonix has a long-term relationship with the CMS, and this is supported with Audiotonix employees based 100% on site. The onsite presence is there to assist the daily running of production, but also to support audits of our tier 2 suppliers, ensuring they are compliant to our supplier code of conduct. The audit process covers all aspects of supply chain controls including local and global labour laws, Health & Safety policies and general working conditions for employees. The CMS supplier has signed up to the globally recognised labour policy – Social Accountability System SA 8000:2014 – that ensures they maintain social values across their organisation. The SA 8000:2014 is regularly audited by accredited external test partners.

After China, the UK makes up the second largest amount of spend across the group at 29%. The majority of this spend is with the brands that have UK manufacturing sites; DiGiCo, Solid State Logic and Calrec Audio. 21% of the UK spend is with a metal work supplier and CEM (Contract Electronics Manufacturer) based in Scotland that support the UK brands. The remaining spend is predominantly with component distributors based in the UK.

Policy

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another, in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings. We are committed to implementing and enforcing effective systems and controls to validate that modern slavery practices are not taking place anywhere in our own business or in any of our direct supply chains.

Audiotonix is committed to upholding the highest standard with our customers, our employees, and the communities in which we live in and serve. A large proportion of our products are used in the entertainment industry, which brings enjoyment into people’s lives. We, therefore, wish to confirm we have taken the appropriate steps to ensure our products are produced to the highest standards and ethics.

We are wholly committed to having an effective process and controls in place to monitor that our supply chain is free from any form of Modern Slavery.

Supply chain understanding

To be a supplier to any Audiotonix group company suppliers must sign up to supplier code of conduct. Once a supplier is approved, if appropriate, we will carry out an onsite inspection audit to ensure the supplier is acting in accordance with our policies and procedures.

Only experienced purchasing professionals are approved to engage with any vendor, while our Audit Teams visiting suppliers to review compliance are drawn from the Audiotonix operations team comprising of Purchasing Managers, Quality Managers and engineers as well as company Directors.

In keeping with our commitment to act with integrity in all our business dealings, we confirm that there is no slavery or human trafficking in any part of our business and audit to confirm that this is also true for our supply chains.

It is our aim to ensure our supply chains are free from slavery, and the company policy is to visit on a regular basis, vendors with whom we have direct and indirect relationships in an effort to validate that:

No forced or bonded labour is used
No child labour is used

In addition, we ensure that supplier organisations take their Environmental, Social, and Governance (ESG) seriously and that they confirm that:

Workers’ conditions are safe and hygienic
No excessive hours are worked
No discrimination is practised
Regular employment is provided
There is no harsh treatment of staff

Audiotonix is committed to having a robust direct supply chain. An essential pillar is that the supplier is operating within all local and international regulations, a key element of which is that the vendor is free from modern slavery and human trafficking. In addition, the Audiotonix Supplier Code of Conduct explicitly sets out what is required, regulatory and ethically, to be an approved Supplier to Audiotonix. The Supplier Code of Conduct requires all main suppliers to sign the document and agree to all of its terms.

Audiotonix is striving to ensure that our supply chain is compliant with the Modern Slavery Act 2015 and confirms that processes are in place to ensure our obligations are met.

In designing a new product, the choice of any material is not just reliant on the technology and cost but also on the supply chain and, therefore, our Purchasing and R&D professionals are involved during the sourcing process.

For unique engineered material we ensure we employ proven manufacturers who comply with local and international regulations on employment including no use of child labour, no bonded labour and no labour in servitude.

Products, sectors and services

The brands within Audiotonix specialise in professional audio mixing solutions and related technologies, including:

Live Sound Consoles: Used in concerts, festivals, and touring events.
Broadcast Mixing Solutions: For live television, sports, and news production.
Studio and Recording Equipment: Including iconic consoles and software plug-ins.
In-Ear Monitoring and Audio Networking: For immersive and personal monitoring experiences.
AI-Assisted Audio Tools: Software that enhances audio production using machine learning.

Audio Capture Devices: For film, TV, and field recording.

In many cases these are sold via distribution and are installed, supplied and supported locally by them, generally as part of a wrapped audio solution.

Direct, and indirect suppliers

The majority of the groups spend is on sub-contract manufacturing based in Asia. The suppliers in Asia provide manufacturing services to supply full turnkey products for direct shipment to distributors along with materials and sub-assemblies for our manufacturing facilities in the UK and USA.

Our main suppliers must sign up to our Supplier Code of Conduct and, as part of this audit, are required to conduct their own audits on their indirect tier 2 & 3 suppliers. This is completed both in person and as a desktop exercise, dependent on the supplier criteria.

Modern slavery risk management governance

Training is provided to the Purchasing, Sales and Management teams annually using a dedicated, developed online educational programme. The training provides a framework using learning outcomes ensuring a consistent approach across all Audiotonix companies to recognise slavery in all its forms and how to challenge and report any infringement of employees’ rights.

Our General Manager of Operations leads on specific efforts to tackle modern slavery within our supply chain, and reports to the UK Chief Operating Officer (COO) who leads on broader efforts across the group. In turn, the COO reports to the main board and CEO.

The board meets monthly and is chaired by an independent Chairman. As part of our overall ESG strategy, all compliance matters, reviews and sign offs are approved by both senior management representatives of all group companies at a monthly operations board that sits alongside our main board.

Information gathering

This stems directly from our audits, AEB compliance checks and referencing of suppliers by our purchasing teams. They go through a 3 stage sign off process before beginning to work with any supplier. The bulk of our raw material purchases are via large distributors, mainly UK based. We spend more on subcontract manufacturing than this, the bulk of which is a HK owned, Dongguan based company who are a Hong Kong listed company and also used by many pro audio manufacturers globally. They produce annual financial and ESG reports which detail their own policies and treatment of their workforce.

Stake holder engagement

First point of internal stake holder engagement is with our R&D and purchasing teams at the very point of looking at the components we wish to design into our products, and the ethical footprint of the supplier itself. This is conducted via referencing but also via our sanction’s compliance program. No supplier can be entered into our ERP system without a certificate from AEB compliance which is verified by each sites head of accounts.

Additionally, we produce annual ESG reports for our external stakeholder investors, banks and for our commitment to reporting in our annual account’s submissions. Within this we cover the number of audits we have adopted and any future plans to expand these.

Continuous Improvement

Audiotonix maintains a structured and proactive approach to managing its direct employees in China, particularly through its relationship with long-term subcontractors, whose labour force is recruited locally within the China region.

Additionally, our chief engineers and management visit our main sub-contractor on an, at least, quarterly basis to ensure direct engagement and oversight of their operations.

Through 2025 a formal modern slavery committee and review will be held quarterly amongst all purchasing managers where we will also review any general compliance changes and updates.

In CY2024, we conducted audits on 32 suppliers (vs. 12 in 2023). In total 261 suppliers have, so far, signed the Audiotonix Code of Conduct. We also enhanced our supplier audit questionnaire by incorporating updated sustainability-related questions to better understand each supplier’s sustainability practices and commitments. Our audit form was updated to cover the Xinjiang area on the relevant points raised, and to mitigate future risks.

No compliance issues have been identified since the last publication of this report.

Identifying and assessing risk

The programme ensuring that compliance continues within the supply chain is undertaken in a structured manner. The highest risk in our supplier base is in non-European territories and therefore our focus is with these vendors. The normal approach is to have on site visits to these companies on an annual basis, utilising the Audiotonix Supplier Audit Checklist form which directs the Audiotonix Auditor on the observations that need to be undertaken during the visit.

The risk assessment will review our key factors in the treatment of employees – freedom of association, the ability to terminate their employment, and also that there is no harassment or violence in the workplace.

The auditor must review the business for no discrimination on gender, ethnicity, sexuality, or religious beliefs.

As the Covid-19 restrictions eased in 2023, the ability to travel internationally resumed. This has enabled on site supplier audits with offshore manufacturers to be undertaken face to face.

Audiotonix also encourages whistleblowing, and this forms an essential part of the Audiotonix Supplier Code of Conduct.

Internal operating policies

All employees accept our employee handbooks on day one of employment. There is no compulsory overtime, and all employees are free to terminate their employment against the notice period in their contract.

The employee handbook includes multiple policies which include:

Code of conduct

Equality & Diversity

Parental Leave

Whistleblowing

Disciplinary Procedures

The Supplier Code of Conduct and the programme of vendor audits ensures that Audiotonix obligations not only meet the Modern Slavery 2015 regulations, but also that their employees are treated with the respect we set under our own commitments. A fundamental part of this policy is the audit attached to it. Our supplier code of conduct additionally includes their confirmation of a Modern Slavery policy in place, or the equivalent policy for non-UK entities.

We enforce our compliance and operating policies via annual compliance training, which is undertaken by key customer, client, supplier facing individuals across our organisations.

Our Whistleblowing policy and internal Suggestion Box allow both internal and external stakeholders to either anonymously or in person report any observations or comments concerning either internal or external concerns they have about fellow employees, suppliers or professionals we work with. All of our policies surrounding Whistleblowing, ABC, AML, Sanctions and Modern Slavery are reviewed annually by independent, external counsel and are available for all employees and contractors to access and review via our websites.

Signed on behalf of Audiotonix Holdings Limited

Helen Culleton

Chief Operating Officer – 30th August 2025