Slavery and Human Trafficking Statement

Briar Chemicals Limited

Anti-Slavery and Human Trafficking statement for financial year ending 31 March 2024

Our Business.

Briar Chemicals Limited (the Company) delivers contract and custom chemical manufacturing solutions to customers across the globe.  From our site in Norwich, UK, we service world-leading companies in the crop protection as well as fine and speciality chemicals sectors, utilising a broad asset and technology base, underpinned by quality driven project management.  Our Company Vision and Values define what we aspire to be as an organisation, how we work within our organisation and our interactions with all other stakeholders.

The Company has a zero-tolerance approach to slavery and human trafficking.  We are committed to acting ethically in all aspects of our business operations and supply chain.  We expect the same high standards from all our contractors, suppliers and other business partners in respect of such exploitation.  They are also required to comply with the provisions of the Modern Slavery Act 2015, and we expect them to hold their own suppliers to the same high standards.

Our supply chain

The supply chain of any chemical manufacturer is complex and raw materials can go through multiple levels of suppliers before entering the manufacturing process. We have a strict policy for the selection of suppliers for both direct and indirect goods and services including recruitment agencies, training providers and consultants.

We expect our suppliers to have procedures in place to ensure modern slavery or trafficking is not taking place in their business or supply chain.   In the preceding 12 months we have reviewed our supply base of direct materials to ensure that our approved supplier lists are up to date and relevant, and any suppliers which have not been used for 24 months are removed from use until they are assessed again in future.

Policies

We are committed to compliance with all relevant legislation and to act with integrity in all aspects of our business dealings.  Many of our existing policies and procedures encompass aspects of our commitment to ensuring employees are treated in a fair and equal manner and explain how we comply with all laws on treatment of employees.  The policies provide employees with the necessary information and support to best recognise exploitation and to ensure there is no slavery or human trafficking in our business or supply chain. The relevant policies include:

• Human Rights Policy
• Anti-corruption Policy
• Recruitment and Induction Policy
• Equal Opportunities Policy
• Procedures for the appraisal and approval of vendors

We continually review and update our policies as necessary to improve our induction programme for new employees to ensure the organisation maintains our high standards for addressing any modern slavery and human trafficking issues that could arise.

Risk Appraisal

As a UK based company with strict HR policies and procedures for recruitment of staff, we work closely with reputable organisations to carry out strict compliance checks to verify the identity of each potential employee. We also ensure that all candidates are legally entitled to be employed.  All prospective employees are required to provide original documentary evidence.

Due to this screening, our main area of risk has been identified as being within our raw material supply chain.

Due to the global nature of the supply chain, we take a risk-based approach to supplier vetting and auditing.  Higher risk suppliers are identified metrics such as industry, legal entity location, manufacturing location or the country of origin for the supply of main raw materials.  Our supply base has remained stable since last issuing this statement.

Our approach – due diligence and monitoring of policy effectiveness

Over the past twelve months we continue to include statements in our supplier assessment forms to request information on how potential new suppliers ensure that modern slavery and human trafficking is not taking place in their own business. We also obtain copies of their due diligence procedures covering how our suppliers monitor their own supply chains.

Once suppliers are selected, approved supplier lists are regularly reviewed and audit requirements are agreed internally.  The suppliers in high risk industries or locations are scrutinised further, this can include periodic audits of tier one suppliers.

The number of suppliers that Briar Chemicals uses has been decreasing year on year, this helps Briar concentrate on effective monitoring of its supply chain.

Training

We will keep employees informed and raise awareness on how to recognise and respond to any indicators of human rights abuse including how to voice any concerns.  We are committed to protecting employees and will ensure all disclosures are treated confidentially without fear of retaliation.  Where required, we will provide training to our staff with a particular focus on senior management, Commercial, HR and Procurement.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s Slavery & Human trafficking statement for the financial year ending 31 March 2024.

C Fazekas, Chief Executive Officer

Date: 29 July 2024