UK Modern Slavery Act

We at MacDermid Autotype have taken several important steps to combat slavery and human trafficking.

UK MODERN SLAVERY ACT STATEMENT

We at MacDermid Autotype Ltd. (UK) (“MacDermid Autotype”) have taken several and important steps to combat slavery and human trafficking. However, we recognize that this is an ongoing process and additional work can and should be done to improve our practices. Therefore, MacDermid Autotype has commenced several activities to further our efforts to address this important issue. MacDermid Autotype is committed to ensuring its supply chain is free from slavery and human trafficking.

I. Organisation’s structure

The MacDermid Autotype supply chain utilizes a global supply base. These suppliers deliver raw materials as well as semi-finished and finished components and products. MacDermid Autotype has surveyed many suppliers to ensure they have adequate anti-slavery and human trafficking policies and procedures. Additionally, MacDermid Autotype has instituted a global Supplier Code of Conduct which mandates various social compliance requirements, including a prohibition of using slave labour in our supply chain. MacDermid Autotype also selectively audits suppliers to help ensure compliance.

II. Our supply chains

The MacDermid Autotype supply chain utilizes a global supply base. These suppliers deliver raw materials as well as semi-finished and finished components and products. MacDermid Autotype has surveyed many suppliers to ensure they have adequate anti-slavery and human trafficking policies and procedures. Additionally, MacDermid Autotype has instituted a global Supplier Code of Conduct which mandates various social compliance requirements, including a prohibition of using slave labour in our supply chain. MacDermid Autotype also selectively audits suppliers to help ensure compliance.

III. Our policies on slavery and human trafficking

MacDermid Autotype is committed to ensuring that the supply chain is free from slavery and human trafficking and has a zero-tolerance policy for the use of slavery and human trafficking in the manufacture of its products. The Anti-Slavery and Human Trafficking Policy reflects commitment to acting ethically and with integrity in all business relationships and to implementing and enforcing effective systems and controls to ensure that slavery and human trafficking is not taking place anywhere in the supply chains worldwide.

MacDermid Autotype’s Anti-slavery and Human Trafficking Policy can be found here.

Additionally, employees and contractors must abide by the Business Conduct and Ethics Policy (employees) and Business Conduct and Ethics Policy (contractors). The Business Conduct and Ethics Policy prohibits the use of slave or trafficked labour.

IV. Due diligence processes for slavery and human trafficking

As part of MacDermid Autotype’s initiative to identify and mitigate risk there are systems in place to:

  • Identify and assess potential risk areas in supply chains.
  • Mitigate the risk of slavery and human trafficking occurring in supply chains.
  • Monitor potential risk areas in supply chains.
  • Protect whistle blowers.

To further illustrate, MacDermid Autotype recently surveyed many of its suppliers’ anti-slavery and human trafficking compliance programs and policies. Additional emphasis was placed on suppliers located in countries that are perceived to have a higher likelihood of slavery and human trafficking issues. MacDermid Autotype is presently satisfied that its suppliers have devoted sufficient attention and resources to this important issue.

MacDermid Performance Solution’s worldwide quality organization also monitors the supply base. This includes auditing suppliers when concerns arise regarding their adherence to requirements. For example, if products are not meeting the applicable specifications a detailed audit is performed. During such audits, a supplier’s social compliance efforts, including anti-slavery and human trafficking, will be reviewed pursuant to a standardized checklist. The quality organization performs similar audits of MacDermid Performance Solution’s facilities.

MacDermid Autotype’s Supplier Code of Conduct requires suppliers to have policies and procedures so that employees can raise concerns without fear of reprisal. Retaliation against whistle blowers is explicitly prohibited by the policy.

V. Supplier adherence to our values

MacDermid Autotype has zero tolerance to slavery and human trafficking. To ensure all those in the supply chain and contractors comply with these values, MacDermid Autotype has in place a supply chain compliance programme. This consists of:

  • Pre-contract screening. As part of standard practice all potential suppliers and other third parties are screened before providing goods or services to MacDermid Autotype. This includes determining if the potential supplier is a specially designated national on various lists maintained by governments around the world. These lists track companies and individuals who are believed to be terrorists, drug traffickers or have committed human rights violations.
  • Supplier Survey. MacDermid Autotype recently surveyed many suppliers assessing their policies and procedures regarding anti-slavery and human trafficking. Based upon the results of this survey MacDermid Autotype is presently satisfied by the efforts of its supply chain
  • Quality Department Audits. MacDermid Performance Solutions’ global quality department audits suppliers. These audits are performed on suppliers who are not meeting the requirements, and going forward, suppliers will be selected randomly. Anti-slavery and human trafficking compliance is an integral part of the audits.
  • Supplier Code of Conduct. MacDermid Autotype has recently instituted a worldwide Supplier Code of Conduct. This Code of Conduct prohibits the use of any slave, forced, trafficked, involuntary prison, indentured (including debt bonded) labour in the supply chain. Suppliers will be asked to acknowledge receipt and certify their ongoing compliance.

MacDermid Performance Solutions has a compliance team, which consists of involvement from the following departments:

  • Operations
  • Procurement/Sourcing
  • Quality
  • Compliance
  • Business Unit Management
  • Legal
  • Human Resources

VI. Training

Staff are trained to ensure a high level of understanding of the risks of modern slavery and human trafficking in the supply chain and to the business. Future efforts will include training suppliers in the Supplier Code of Conduct. Suppliers will also be required to provide training to their employees.

VII. Effectiveness in combating slavery and human trafficking

MacDermid Autotype is implementing a new rating system (scorecard) for suppliers that includes several social compliance metrics. One of the metrics rates the supplier on the ability of employees to freely terminate their employment with a supplier. The supplier will be required to perform a self-assessment in addition to the rating made by MacDermid Autotype. A supplier’s score will be used to determine if remedial action needs to be taken. Because of the zero-tolerance policy business relationships will be terminated if a supplier is found to be using forced, trafficked or slave labour.

VIII. Further steps

Following a review of the effectiveness of the steps taken over the last two years, to ensure that there is no slavery or human trafficking in the supply chain, the following additional steps to combat slavery and human trafficking will be taken:

  • Additional Audits – Increasing the number of audits as well as auditing suppliers randomly.
  • Scorecard – Suppliers will perform a self-assessment and will be graded against specific criteria, including involuntary labour.
  • Certifying Compliance – Suppliers will be asked to acknowledge the Supplier Code of Conduct and certify their ongoing compliance.
  • Training – MacDermid Autotype will conduct supplier training sessions covering the Supplier Code of Conduct. This training will include the prohibition of slavery and human trafficking in the supply chain.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st December 2016.

Joe Headon, Operations Director

MacDermid Autotype Ltd

Date: 31st July 2017