Modern Slavery Act Statement 2025
This Modern Slavery Act Statement is published by Colorcon Limited in compliance with Section 54(1) of the UK Modern Slavery Act 2015 (“the Act”) and relates to the financial year ending 31 December 2025.
Colorcon, Inc. (“Colorcon”), and its subsidiaries, including Colorcon Limited (collectively, the “Company”), is committed to responsible sourcing and to the prevention of human trafficking and slavery in its business and supplier network. The Company addresses modern slavery risk through a number of means.
The Company’s Code of Business Conduct requires Company employees to comply with all laws in the jurisdictions in which the Company does business, which would include those laws regarding the use of labour. Further, the Code of Business Conduct provides several options for reporting suspected violations including a Business Conduct Hotline accessible by phone and through a website. In addition, the Company’s Corporate Responsibility Statement and Guidelines prohibit the Company’s use of child or forced labour.
The Company introduced a supplier code of conduct (“Supplier Code of Conduct”) in May 2023, pursuant to which suppliers are required, at a minimum, to comply with all applicable laws and regulations regarding working conditions and labour standards. Where local laws are less stringent than the International Labour Organisation (“ILO”) Fundamental Principles, the Supplier Code of Conduct provides that the ILO’s Fundamental Principles will apply unless prohibited by local laws.
All new suppliers are required to comply with our Supplier Code of Conduct. The Company has made significant progress in having existing suppliers adopt our Supplier Code of Conduct or submit their own equivalent policy, which the Company reviews and confirms as compliant. We continue to work with the remaining suppliers towards adoption of our Supplier Code of Conduct.
The Company’s standard supplier contract, currently in place with a number of its suppliers, requires the supplier to comply with all applicable laws in the jurisdictions in which the supplier produces and sells its products. In the standard supplier contract, the Company retains audit rights with regard to the supplier’s compliance with the contractual provisions. In addition, the Company’s standard terms and conditions of purchase require sellers to warrant that all goods purchased by the Company have been manufactured in compliance with all applicable laws.
The Company has implemented its risk assessment with suppliers of raw materials as part of its global responsible procurement framework (CARPE – Colorcon’s Action for Responsible Procurement Engagement). The risk assessment segments suppliers into high, medium, or low risk for corruption, slavery, environmental concerns, and forced labour and child labour. The Company also continues to monitor its direct suppliers of raw materials in China and has not identified any materials sourced from the Xinjiang Uyghur Autonomous Region.
The Company uses a training platform to deploy and track training of employees. Relevant training is provided to employees based on their roles. Training includes the Company’s Code of Business Conduct, which is mandatory for all new employees. Additional training regarding sustainability,
sustainable procurement and supplier screening is provided for relevant job roles. The Company also provides supplier forced labour training to suppliers in certain higher-risk regions.
The Company regularly reviews its policies and procedures to evaluate and address risks of forced labour and child labour. There have not been any complaints for the 2025 fiscal year with regards to suspected or actual wrongdoing as defined in the Act.
The above statement was approved by the board of directors of Colorcon Limited on 22nd June 2026.
On behalf of Colorcon Limited
Name: Stephen Batchelor
Director
