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.z o.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 its business and supply chain, and imposes the same high standards on its suppliers. This annual statement is made as part of its public commitment to promote human rights and pursuant to s54 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 2022 and ending 31 March 2023 (“FY22”).
2. Our Business
SPCEU Group develops and manufactures plastic compounds; employs approximately 285 people; and has a global annual turnover in the region of €175M. To find out more about the nature of our business, please click www.sumikaeurope.com.
Effective 31 March 2023, SPCEU became a wholly-owned subsidiary of Sumitomo Chemical Company Ltd (“SCC”). SCC group of companies (“SCC Group”), comprises 170 subsidiaries and operates worldwide in five business sectors – petrochemical, energy & functional materials, IT-related chemicals, health & crop sciences and pharmaceuticals – and provides products worldwide that support a wide variety of industries and help people’s daily lives.
SCC Group has a number of group companies operating in the United Kingdom performing different functions, including SPCEU, SPCUK, Sumitomo Chemical (UK) plc and Cambridge Display Technology Limited. SCUK is a distributor of household and professional-use insect control products for the Environmental Health Division of SCC.
3. Our Supply Chain
SPCEU Group purchases various raw materials including polymers, chopped strand glass fibre,
minerals such as talc and chalk, coupling agents, colourants, and other chemical additives supplied by its affiliates in SCC Group and by non-group third parties.
4. Policies
The SPCEU Group follows the code of conduct of SCC Group.
The SPCEU Group categorically rejects modern slavery, including forced, bonded or forced labour, bondage, deceptive employment, lineage slavery and human trafficking. As part of our commitment to combating modern slavery, we have in place a code of conduct which sets forth a requirement that all relevant personnel must respect the human rights of others and comply with applicable laws, regulations and ethical standards.
In April 2019, the SCC Group established the “Sumitomo Chemical Group Human Rights Policy” based on the Universal Declaration of Human Rights, the International Labour Organization 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, that includes the prohibition of forced labour and child labour.
The SCC Group statement against Modern Slavery and Human Trafficking can be accessed by clicking statement_20220401e-1.pdf (sumitomo-chem.com.sg)
SPCEU Group has in place a reporting system to capture, at an early stage, signs of compliance
violation, including any concern of SPCEU Group’s business having been involved in modern slavery or human trafficking, and to make sure those issues detected are removed promptly and appropriate measures are taken swiftly. Under our Speak-Up Reporting System any employee or third party can report any violation or suspected violation of compliance to the compliance committee or other similar governing committee through several different internal and external channels, including an external platform available for suppliers and anyone having any involvement in the companies’ business activities to report any concerns.
5. Due diligence
It is SPCEU Group’s policy to only procure supplies such as raw materials and packaging materials from suppliers that operate their business in a socially responsible manner, including operating their business free from modern slavery or human trafficking. As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have due diligence procedures which are 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;
• provide adequate protection for whistle-blowers.
The standard contractual terms of SPCEU Group, incorporate human rights provisions that require our supply chain to promise and confirm their compliance with laws and regulations in respect of management of human rights risk including prohibition of modern slavery, human trafficking, forced labour and child labour.
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 recognise the risks of modern slavery and human
trafficking in our business and supply chains. Through our training programmes, employees are
encouraged to identify and report any potential breaches of our anti-slavery and human trafficking policy. In FY22, the majority of our employees were trained on issues concerning slavery and human trafficking, as well as the consequences of failing to eradicate these issues from our business and supply chains.
8. Effectiveness and KPIs
During this reporting year:
• Across the SPCEU Group, no suppliers have objected to the inclusion of standard contractual
anti-slavery wording or required substantive amendments.
• SPCUK assessed 100% of its new suppliers’ anti-slavery policies and processes.
• Based on risk assessments of geographical location and operational activities, SPCUK has
visited two existing suppliers to observe their operations and talk with employees on matters
relating to human rights.
• SPCTR carried out a risk assessment of its suppliers and has focussed its communication
efforts on suppliers of recycled materials including those in territories which are considered
higher risk.
• SPCPL has undergone an external assessment of workplace conditions and achieved an average score of 97%. No areas of improvement in relation to labour and wages and hours were identified.
• The programme of training of staff across the SPCEU Group in identifying and mitigating risks
of modern slavery has continued. This principally includes online training from a leading external training provider. In addition, we have developed a tailored training package for non- desk-based colleagues located in Turkey which was delivered face-to-face.
9. Looking Ahead
The SPCEU Group believes that the promotion of respect for human rights and ensuring compliance with applicable laws, regulations, and ethical standards, including those relevant to modern slavery and human trafficking, is vital for operating its business in a sustainable manner. As such, SPCEU Group will continue its initiatives as described above, to identify and address any issues associated with modern slavery and human trafficking throughout its operations and supply chains.
This statement is made annually, and a new statement is expected to be published in September 2024.
This statement was approved by the Board of Directors of SPCEU on 27/09/2023.
Ludovic Seynave
President
Sumika Polymer Compounds (Europe) Limited
Date: 27 September 2023