Modern Slavery Act Statement 2024
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 it relates to the financial year ending 31 December 2024.
Colorcon, Inc. (“Colorcon”), and its subsidiaries, including Colorcon Limited (collectively, the “Company”) are committed to responsible sourcing and to the prevention of human trafficking and slavery in its supply chain. The Company addresses this issue 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 policy (“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. In 2024 a substantial number of the Company’s existing suppliers either adopted our Supplier Code of Conduct or submitted their own equivalent policy which we reviewed and confirmed 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.
In addition, the Company redesigned and implemented its supplier of raw materials risk assessment as part of its sustainable procurement policy. The new risk assessment segments suppliers into high, medium, or low risk for corruption, slavery, environmental issues, and forced labour and child labour.
The Company uses training platform to deploy to, and track training of, relevant employees periodically on modern slavery and human trafficking, the Company’s Code of Business Conduct, sustainability and sustainable procurement, and supplier screening.
The Company regularly reviews its policies and procedures to evaluate and address risks of forced labor and child labor. There have not been any complaints for the 2024 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 _June 2025.
On behalf of Colorcon Limited
Name: Stephen Batchelor
Director
