Sumika Polymer Compounds Europe > Anti slavery act

Sumika Polymer Compounds Group Statement against Modern Slavery and Human Trafficking

1. About the Statement

Sumika Polymer Compounds (Europe) Ltd (“SPCEU”, “we”, “our”) and its subsidiaries (together, the “SPCEU Group”), Sumika Polymer Compounds (UK) Ltd (“SPCUK”), Sumika Polymer Compounds (France) S.A. (“SPCFR”), Sumika Polymer Compounds (India) Pvt Ltd (“SPCI”), Sumika Polymer Compounds Poland Sp.zo.o. (“SPCPL”), Sumika Polymer Compounds Turkey Plastik Sanayi ve Ticaret A.S. and Almen Plastik A.S (together, “SPCTR”), are fully committed to promoting human rights and preventing acts of modern slavery and human trafficking from occurring within our business and supply chain, and impose the same high standards on our suppliers. This annual statement is made as part of our public commitment to promote human rights and pursuant to Section 54 of the UK Modern Slavery Act 2015 and the U.S. California Transparency in Supply Chains Act of 2010. This statement is made for the financial year commencing 1 April 2024 and ending 31 March 2025 (“FY24”).

2. Our Business

The SPCEU Group develops and manufactures plastic compounds; employs approximately 300 people and has a global turnover of €160 million. To find out more about the nature of our business, please click www.sumikaeurope.com.

SPCEU is a wholly owned subsidiary of Sumitomo Chemical Company Ltd (“SCC”). The SCC group of companies (“SCC Group”) comprises 160 subsidiaries and operates worldwide in four business sectors – Agro & Life Solutions Sector, ICT & Mobility Solutions Sector, Advanced Medical Solutions Sector, Essential & Green Materials Sector – and provides products worldwide that support a wide variety of industries and help people’s daily lives.

The SCC Group has a number of group companies operating in the United Kingdom performing different functions, including SPCEU, SPCUK, Sumitomo Chemical (UK) Ltd (“SCUK”), and Cambridge Display Technology Limited. SCUK is a distributor of household and professional-use insect control products for the Agro & Life Solutions sector of SCC.

3. Our Supply Chain

The SPCEU Group operates in various locations and purchases raw materials, including polymers, chopped strand glass fibre, minerals such as talc and chalk, coupling agents, colourants, and other chemical additives. These materials are supplied by both affiliates within the SCC Group and external third-party vendors. Recognizing the importance of effective supply chain management for sustainable business operations, the SPCEU Group adheres to the SCC Group’s procurement standard, which prioritises sourcing from suppliers actively engaged in sustainability initiatives. This policy, outlined in the Group Business Standard of Procurement, guides procurement activities for SCC Group companies in Japan and internationally.

4. Policies

The SPCEU Group adheres to the SCC Group’s Code of Conduct and firmly rejects all forms of modern slavery, including forced labour, bonded labour, deceptive employment practices, lineage slavery, and human trafficking. As part of our commitment to combating modern slavery, we enforce a Code of Ethics that mandates all personnel to respect human rights and comply with all applicable laws, regulations, and ethical standards.

In April 2019, the SCC Group established the “Sumitomo Chemical Group Human Rights Policy” which is grounded in the Universal Declaration of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, the Ten Principles of the United Nations Global Compact, and the United Nations Guiding Principles on Business and Human Rights. This policy explicitly prohibits forced labour and child labour. The SCC Group statement against Modern Slavery and Human Trafficking can be accessed by clicking statement_20250401e.pdf.

The SPCEU Group has established a reporting system to detect and address potential compliance violations at an early stage. This system includes mechanisms to report any concerns related to the Group’s involvement in modern slavery or human trafficking. It ensures that identified issues are promptly addressed and appropriate corrective actions are taken swiftly. Our Speak-Up Reporting System allows employees and third parties to report any violations or suspected violations of compliance to the compliance committee or a similar governing body. Reports can be submitted via multiple internal and external channels, including an external platform available to suppliers and anyone involved in the company’s business activities.

Speak-up ! – Sumika Polymer Compounds Europe

5. Due diligence

SPCEU Group’s policy is to only procure supplies such as raw materials and packaging materials from suppliers who operate their business in a socially responsible manner, including operating their business free from modern slavery or human trafficking. As part of our commitment to monitoring and mitigating the risks of slavery and human trafficking occurring within our supply chains, we have established due diligence procedures designed to:

– Establish and assess areas of potential risk in our business and supply chains.

– Reduce the risk of slavery and human trafficking occurring in our business and supply chains.

– Ensure robust protection for whistle-blowers.

The standard contract terms and conditions of the SPCEU Group incorporate human rights provisions that require our supply chain to promise and confirm their compliance with laws and regulations in respect of the management of human rights risk. This includes the prohibition of modern slavery, human trafficking, forced labour, and child labour.

The SPCEU Group Terms and conditions can be accessed by clicking the following link:  Legal & Compliance – Sumika Polymer Compounds Europe.

6. Risk and compliance

SPCEU evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain by undertaking periodic surveys of the companies that supply its subsidiaries regarding their anti-slavery policies and processes.

Where we identify a potential risk with a supplier, we engage with them to establish appropriate measures and actions to address the risk, which may include focussed requests for improvement and/or offering to provide guidance and training to our suppliers and their supply chain. By seeking to raise awareness and cooperation in ensuring responsible procurement, SPCEU aims to prosper alongside our suppliers.

7. Training

We have invested in educating our staff to recognize the risks of modern slavery and human trafficking within our business and supply chains. Our training programmes encourage employees across all group companies to identify and report potential breaches of our anti-slavery and human trafficking policy, ensuring strict compliance with applicable laws, regulations, and ethical standards. By the end of FY24, the majority of our employees received training on these critical issues. SPCEU remains committed to providing timely and regular internal and external training, with the goal of having all employees complete or refresh their anti-slavery training by the due date.

8. Effectiveness and KPIs

During this reporting year:

1. Across the SPCEU Group, no suppliers have objected to the inclusion of standard anti-slavery clauses in contracts, nor have any requested substantive amendments
2. As part of our ongoing supplier compliance efforts, SPCUK and SPCEU assessed 100% of new suppliers through a detailed modern slavery questionnaire and desktop research, while 97% of existing suppliers have completed modern slavery checks, with a monthly review and three-year revalidation cycle ensuring continued oversight; no concerns were identified during these assessments.
3. Based on SPCTR’s risk assessment of its suppliers, the ongoing focus has continued on suppliers of recycled materials, particularly those in higher-risk territories. Frequent visits are made to these areas, and, during the year, 21 new and existing suppliers were visited in person including five key high-volume recycled raw material suppliers. There were no concerns noted during the visits.
4. All our employees at SPCTR received refresher training on the Speak-Up policy, with specific focus on modern slavery and the available reporting channels.
5. The training program for staff across the SPCEU Group in identifying and mitigating risks of modern slavery has continued with 57% of all staff receiving new and refresher training on the subject, bringing the total number of staff with completed training to 83%. The program is now established as an annually recurring requirement across the group.
6. To mitigate risks associated with suppliers and customers, and as a responsible company committed to taking precautionary measures, we have extended our onboarding survey to include a Modern Slavery section and to review the policies implemented across the company, including the whistleblower/speak-up system. This initiative has been implemented across the SPCEU Group.
7. Within SPCUK, site visits have been made to three suppliers who were classified as higher risk due to the nature of the supply. No concerns were identified.
8. The trading Terms and Conditions for sales and purchases of the SPCIN entity have been revisited, with additional elements of Modern Slavery and Human Trafficking incorporated and disclosed on the company’s website.
9. At SPCTR, modern slavery awareness has been included as a regular agenda item in the Compliance meetings every quarter.
10. During the Group Compliance promotion initiative, a message from our senior leadership team was shared with all employees across the SPCEU Group, reaffirming our zero-tolerance approach to Modern Slavery and Human Trafficking and our commitment to working only with partners who share our dedication and uphold our rigorous due diligence standards.
11. As part of our continued efforts to strengthen governance and uphold human rights, the SPCEU Group reviewed and updated its Code of Ethics during the relevant fiscal year to explicitly incorporate provisions addressing Modern Slavery and Human Trafficking. This enhancement underscores our commitment to maintaining ethical standards across our operations and supply chains. The updated Code was communicated to all employees, each of whom is required to confirm their understanding and adherence through a signed declaration. This process helps ensure that all staff are aware of their responsibilities in identifying and preventing risks related to modern slavery and unethical practices.

9. Looking Ahead

The SPCEU Group is committed to promoting respect for human rights and ensuring compliance with all applicable laws, regulations, and ethical standards, including those related to modern slavery and human trafficking. We believe these principles are vital for operating its business in a sustainable manner. As such, the SPCEU Group will continue its initiatives to identify and address any issues related to modern slavery and human trafficking throughout our operations and supply chains.

This statement is made annually, and a new statement is expected to be published in September 2026.

This statement was approved by the Board of Directors of SPCEU on 16 September 2025.

Ludovic Seynave

President

Sumika Polymer Compounds (Europe) Limited

16 September 2025