Modern Slavery & Human Trafficking Statement

Purpose of this Statement
The purpose of this document is to outline Scanmetals’ commitment and actions to tackle the risks associated with modern slavery and human trafficking within its operations and supply chains. Scanmetals is dedicated to comprehensively understanding and addressing these risks to ensure that no form of slavery exists within our business, or those we work with. 

As part of our commitment, we vehemently oppose forced labour, bonded labour, involuntary prison labour, slavery, servitude, or any form of trafficking against individuals’ will. To reinforce this commitment, we have established principles aligned with applicable laws and regulations, shaping our practices to combat modern slavery and human trafficking within our operations and supply chains. These principles are embedded in our company’s codes and policies, guiding our employees’ conduct throughout their tenure at Scanmetals group of companies.

Our Business and Supply Chains
Scanmetals is a specialist metals recycling company, recovering non-ferrous metal from post-consumer waste. The recovered non-ferrous metals are cleaned, separated into different fractions, and sold to primary and secondary smelters, refineries, ingot makers and foundries globally.  By virtue of the wide variety of activities undertaken within Scanmetals, working with a variety of metal commodities, organisations and end users, we form an intrinsic part of (and are supported by) a diverse range of supply chains. 

Policies in Relation to Slavery and Human Trafficking
The policies we currently have in place ensure our own staff, suppliers, partners and others who are directly linked to our business are aware of our strong stance against unethical practices, modern slavery and human trafficking. 

• The importance of people: People are a key factor for our business to succeed and we foster a culture of improvement and growth by encouraging training and progression within the organisation. We avoid the use of “zero hours” contracts and ensure that remuneration for employees meets or exceeds the applicable legal minimum – this is part of our commitment to retaining staff in fairly paid and stable jobs.
• Child Labour: Scanmetals condemns the use of child labour and does not employ children in any aspect of our business.
• Equality of opportunity: Scanmetals is committed to a policy of equal opportunity in all aspects of employment and the policies we have in place are applied to all aspects of work, including recruitment and selection, pay, benefits, and opportunities for training and discipline.
• Transparency and accountability: We are committed to conducting our business with honesty and integrity and we expect all staff to maintain high moral and ethical standards as representatives of the company. We have adopted a Whistleblowing policy to foster a culture of openness, accountability without fear of reprisal. This ensures that all policies adopted in our business can be appropriately implemented and enforced.
• Modern Slavery and Human Trafficking as a global issue: We recognise that combatting modern slavery and human trafficking is a challenge, not just within our group of companies but also throughout the supply chains we are part of. We ensure none of our business transactions are party to practices that contravene our policies on modern slavery and human trafficking.

Due Diligence
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted the following due diligence practices:  

• We undertake reviews when considering taking on new suppliers and customers.
• We conduct audits of our existing suppliers and customers to ensure they are compliant with applicable laws and regulations. including in relation to modern slavery and human trafficking.
• We monitor potential risk areas in our business and supply chains concerning modern slavery and human trafficking.
• We proactively reduce the risk of slavery and human trafficking occurring in our business and supply chains and provide adequate protection for whistle blowers.

The due diligence exercises described above are undertaken by members of the business involved in the relevant supply chain and consider their judgement as to what scope of due diligence is necessary in the relevant circumstances.

Compliance and Risk Management
We regularly evaluate the nature and extent of our exposure to the risk of modern slavery occurring in our supply chain by reviewing the policies outlined above, communicating our expectations and values to participants in our supply chains, and reviewing our due diligence checks and working practices.  

We do not tolerate slavery and human trafficking within our supply chains. If we find evidence of a failure by a supplier or customer to comply with relevant slavery and human trafficking policies or laws and regulations, we will consider how to most appropriately address this non-compliance. In some instances, we may require suppliers or customers to take immediate action to remediate the issues identified; in others, we may seek to terminate our relationship with the relevant supplier or customer immediately.

In line with the OECD Guidelines for Multinational Enterprises we adopt a risk-based approach to due diligence of suppliers and customers, including in relation to modern slavery and human trafficking. In areas where the risk is deemed to be high, further detailed due diligence is undertaken together with supply chain certification where necessary. In line with this risk-based approach our current due diligence principles are as follows:

• Supply chain participants based in the UK and EU are expected to have adopted appropriate modern slavery and human trafficking policies. These are considered low risk.
• Supply chain participants based in OECD member countries or countries that are known to have adopted the OECD Guidelines are expected to be low risk and, as a minimum, are expected to comply with relevant employment legislation of the country where they are based and any specific modern slavery and human trafficking regulations.
• Supply chain participants based in countries where compliance with OECD Guidelines is unknown, are considered to be a medium to higher risk with regard to modern slavery or human trafficking activities. They are required to confirm adherence to our policies or a comparable policy addressing the same concerns. Where appropriate, written evidence of such a policy is not available, additional due diligence may be undertaken to determine substantive compliance with applicable modern slavery and human trafficking requirements.

Performance Indicators
Considering continued improvement of our policies and procedures, we do not consider it appropriate to impose KPIs at the present time while these are being implemented.

Training and Reporting
We require all staff within Scanmetals to understand the implications of issues associated with modern slavery and we will provide training as required.

Employees can report suspicions of slavery or human trafficking directly to their line manager, senior management or directly to the board of directors without fear of reprisals. Additionally, they may report suspicions using our whistleblowing procedure.

Our management systems and operating procedures will be regularly reviewed to ensure our working practices safeguard our people, the environment and effectively manage sustainability issues. The board of directors of Scanmetals A/S and all subsidiary companies are committed to ensuring Scanmetals’ activities are conducted in accordance with this statement.

ALL EMPLOYEES AND CONTRACTORS MUST FAMILIARISE THEMSELVES WITH THE CONTENT OF THIS STATEMENT AND ALL APPLICABLE AND RELEVANT PROCEDURES SUPPORTING THIS STATEMENT