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Modern slavery statement

Modern slavery and human trafficking statement

Annual statement on the steps ERAM Group takes to ensure that modern slavery and human trafficking are not taking place in our operations or in our supply chain. Aligned with the UN Guiding Principles on Business and Human Rights and the ILO core labour standards.

Draft template — legal counsel review required. This page is a structural draft prepared to the framework of GDPR (Regulation EU 2016/679), the EU Whistleblower Directive (2019/1937) where relevant, and applicable Kosovo law. It is not legal advice. Final text must be reviewed and approved by qualified legal counsel before publication.

1. Our business

ERAM Group Ltd. is an authorised technical distributor headquartered in Pristina, Republic of Kosovo. We distribute HVAC-R, electrical, plumbing, energy, safety, industrial, and adjacent product categories sourced under authorised agreements from international manufacturers, and sell to B2B contractors, EPCs, and resellers, with retail sold through our e-commerce property.

2. Our policies

We do not tolerate modern slavery, forced labour, debt bondage, child labour, or human trafficking in any part of our business or supply chain. Our policies include:

  • Recruitment under a non-discrimination framework consistent with Kosovo Law 05/L-021 on Protection from Discrimination.
  • Right-to-work verification for all employees in line with Kosovo employment law.
  • Direct payment of wages to bank accounts in the employee's own name; no third-party intermediaries.
  • Working time and rest periods consistent with Kosovo Law 03/L-212 on Labour.
  • A whistleblowing channel that accepts confidential reports of modern slavery concerns.

3. Our supply chain

Our principal upstream suppliers are international manufacturers operating under their own modern-slavery frameworks. We expect our suppliers to comply with the ILO core labour standards (forced labour, child labour, freedom of association, non-discrimination) and to maintain their own due-diligence processes.

4. Due diligence

From 2026 forward, ERAM Group is integrating a modern-slavery risk assessment into supplier onboarding and renewal. The assessment is risk-based, with deeper review for suppliers operating in or sourcing from jurisdictions identified as elevated risk by the Global Slavery Index.

5. Training

Procurement, HR, and senior commercial staff receive periodic training on identifying and responding to modern-slavery indicators in the supply chain and in operations.

6. Reporting

Suspected modern slavery in connection with ERAM Group or its supply chain should be reported through the Group's whistleblowing channel or to compliance@eram-group.net. Reports are handled in confidence and with protection against retaliation.

7. Approval

This statement was approved by the Board of Directors of ERAM Group Ltd. on [date] and is signed by the Chief Executive Officer. It will be reviewed and updated annually.

Gazmend Kelmendi, Chief Executive Officer, ERAM Group Ltd. · [Date]