MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT
INTRODUCTION
We are committed to improving our practices to combat slavery and human trafficking. 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 are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We expect the same high standards from all our contractors, suppliers, and other business partners. As part of our third-party contracting processes, we include specific prohibitions against the use of forced and/or trafficked labour and against the exploitation of anyone held in slavery or servitude, whether adults or children. We expect that our suppliers will hold their own suppliers to the same high standards.
ORGANIZATION’S STRUCTURE
We are a leading manufacturer of high-performance elastomers, advanced-engineered thermoplastics, high-performance thermoplastic composites, and integrated material solutions sector. We are a global company with facilities across North America, Europe, and Asia.
We are a part of the Greene Tweed Group (Group), defined as GT Global Holdings, Inc., the parent company, and its subsidiaries. GT Global Holdings, Inc. has its head office in the United States. The Group has over 1,900 employees worldwide.
OUR SUPPLY CHAINS
We work with approximately 2,000 suppliers in multiple countries.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery and Human Trafficking and Ethics Policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk we expect our Suppliers to complete a Supplier Survey and we issue a copy of our Supplier handbook to all Suppliers. Additionally, where increased risk is suspected, we can also perform an audit of the Supplier.
SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our ethics we have in place a supply chain compliance programme. This consists of a Supplier Handbook, Supplier Audits and Supplier Surveys.
The following departments are involved in the continuing monitoring and development of this Statement and all related policies and Supplier reference and compliance materials:
- Legal
- Human resources
- Procurement
TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our Supply Chain employees. This training is mandatory and monitored through Workday to ensure adherence.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
The training that we provide to our Supply Chain employees is regularly reviewed and updated to ensure that it continues to meet our needs and our training includes any updates made to our Supply Chain Handbook. Staff are expected to be alert to the risks in our Company and wider supply chain and to report any concerns to management.
We expect 100% completion of the training, which also forms part of the new hire orientation programme for anyone new to Greene, Tweed, or the Supply Chain function.
We take the responsibility for educating our Suppliers on our expectations very seriously and we have recently updated our Supplier Handbook which will be shared with all our suppliers. We are also updating our Supplier Survey and Auditing materials.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending March 2025.
Jeremy Midwinter
Vice President and Chief Financial Officer
Date: February 2024