Modern Slavery Act Statement 2023
This Modern Slavery Act Statement is published by Colorcon Limited in compliance with Section 54(1) of the UK Modern Slavery Act 2015 (“the Act”) and it relates to the financial year ending 31 December 2023. Colorcon, Inc. (“Colorcon”), and its subsidiaries, including Colorcon Limited (collectively, the “Company”) are committed to responsible sourcing and to the prevention of human trafficking and slavery in its supply chain. The Company addresses this issue through a number of means.
The Company’s Code of Business Conduct requires Company employees to comply with all laws in the jurisdictions in which the Company does business, which would include those laws regarding the use of labour. Further, the Code of Business Conduct provides several options for reporting suspected violations including a Business Conduct Hotline accessible by phone and through a website. In addition, the Company’s Corporate Responsibility Statement and Guidelines prohibit the Company’s use of child or forced labour.
A supplier code of conduct policy was introduced in May 2023, pursuant to which suppliers are required, at a minimum, to comply with all applicable laws and regulations regarding working conditions and labour standards. Where local laws are less stringent than the International Labour Organisation (“ILO”) Fundamental Principles, the Company’s supplier code of conduct provides that the ILO’s Fundamental Principles will apply unless prohibited by local laws.
As of May 2023, all new suppliers are required to comply with the supplier code of conduct and in 2024 existing suppliers will be required to sign the supplier code of conduct as well.
The Company’s standard supplier contract, currently in place with a number of its suppliers, requires the supplier to comply with all applicable laws in the jurisdictions in which the supplier produces and sells its products. In the standard supplier contract, the Company retains audit rights with regard to the supplier’s compliance with the contractual provisions. In addition, the Company’s standard terms and conditions of purchase require sellers to warrant that all goods purchased by the Company have been manufactured in compliance with all applicable laws.
In addition, the Company redesigned its supplier of raw materials risk assessment as part of its sustainable procurement policy in 2023. The new risk assessment segments suppliers into high, medium, or low risk for corruption, slavery, environmental, and forced labour and child labour. Implementation of the updated risk assessment will take place in 2024.
Colorcon Limited is working towards the development of key performance indicators to measure the effectiveness of steps it is taking to address issues relating to modern slavery in its supply chain. Colorcon Limited also provides training to relevant employees periodically on modern slavery and human trafficking.
There have not been any complaints for the 2023 fiscal year with regards to suspected or actual wrongdoing as defined in the Act.
The above statement was approved by the board of directors of Colorcon Limited on 28th June 2024.
On behalf of Colorcon Limited
Name: Stephen Batchelor
Director
