Modern Slavery Act Statement

This statement is pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 and constitutes the modern slavery and human trafficking statement on behalf of Hadley Industries Holdings Limited (“Hadley”) for the financial year ending 31 April 2023.

We have reviewed our last modern slavery and human trafficking statement, and this statement sets out the steps Hadley continues to take and, where appropriate: any new steps it has introduced during the previous financial year to address the risk of modern slavery taking place within its own operations and supply chains.

For the purpose of this statement; joint venture arrangements are treated as being part of our supply chains.

Hadley has a commitment to ensure that there is no modern slavery or human trafficking in its supply chains or in any part of its business and imposes the same high standards on its suppliers.

Hadley is the UK’s largest independent manufacturer of cold rolled metal profiles. We are the parent company of the Hadley Group with its Head Office based in the United Kingdom. The Group operates globally and has over 700 employees based in four countries with a global annual turnover of £180 million.

Our business is organised into three business units:

• Construction: Providers of a range of Structural and Non-Structural products including; steel profiles, steel framing, purlin systems, drylining products, door and window reinforcements; all of which are designed to streamline construction, enhance performance and maximise sustainability.
• Automotive: Providers of roll formed profiles to the automotive market, specialising in the production of demanding and complex components.
• Industrial: Providers of cold roll formed profiles and associated products to the industrial market, specialising in the production of high strength, weight-saving and high-volume components.

Hadley purchases parts, components, services, supplies and raw materials from a significant number of suppliers. Our supply chains are therefore extensive, numbering over six hundred suppliers over six countries. We also use a range of suppliers in the UK including professional services firms. Our UK supply chains include:

• Agency.
• Distribution.
• Procurement of goods and services.
• Outsourcing.
• Sub-contracting.

As part of our commitment to combatting modern slavery and human trafficking, we operate the following policies and procedures, which 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 modern slavery and human trafficking is not taking place anywhere in our operations:

• Whistleblowing Policy – this is aimed primarily at employees, but is also available to others working in our supply chains including customers and business partners in order to encourage the reporting of any suspected wrongdoing related to the direct activities or the supply chains of our organisation without fear of retaliation. This includes any circumstances that may give rise to an enhanced risk of modern slavery or human trafficking.
• Grievance Policy – which in a similar way to the Whistleblowing Policy, allows employees to raise concerns in relation to suspected wrongdoing internally, without fear of retaliation.
• Anti-slavery Policy – this reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place anywhere in our business or supply chains.
• Employee Code of Business Ethics – this is intended to be introduced to employees in the 2020/21 financial year and all new employees will be required to accept the code upon joining the business. The code provides a set of rules to ensure employees are upholding the highest level of ethical conduct in their day to day business.

As part of our initiatives to identify and mitigate risk, we regularly review existing policies and practices as part of our ongoing compliance obligations in producing this statement.

As part of our efforts to monitor and reduce the risk of modern slavery and human trafficking in our business and supply chains, we have adopted the following due diligence procedures:

• We communicate to our Tier 1 suppliers the expected standards in addressing the risk of modern slavery and human trafficking in their supply chains.
• We incorporate compliance with the Modern Slavery Act 2015 as an integral part of our negotiations, and contracts, with such suppliers, regardless of their size. Suppliers who breach this obligation face appropriate action, which could include termination of contracts and/or the business relationship.
• We conduct Tier 1 supplier audits, and invoke sanctions against those suppliers, where appropriate.
• We undertake “right to work” checks for all employees prior to commencing employment. This includes checking, where applicable, that the employee has a valid work visa and is of an appropriate age to work.

Our procedures are designed to:

• Identify and assess potential risk areas in our business and supply chains to include country, business transaction and raw materials risk.
• Mitigate the risk of slavery and human trafficking occurring in our business and supply chains.
• Monitor potential risk areas in our business and supply chains.
• Protect whistleblowers.

As matters stand as at the date of this statement, the above processes have not given Hadley any reason to suspect the existence of modern slavery or human trafficking in its business or its supply chain.

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

• Business function reports.
• Internal staff training and on boarding processes.
• New supplier visits.

We will also continue to monitor and review our practices within our business and supply chains, and if our perception of risk changes, we will revisit our existing practices.

Training will be provided to those employees in roles most likely to be in a position to identify and address potential modern slavery risks, including Human Resources, Sales, Finance, Audit & Compliance, Legal and Procurement functions.

This training is to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and within the business.

We have also built awareness of the risks of slavery and human trafficking within the business and its supply chains into our induction process for all new employees regardless of function.

This statement has been duly approved by the board of directors of Hadley. This statement is issued on their behalf and with their consent.