UK MODERN SLAVERY ACT STATEMENT
2024
We at MacDermid Autotype Ltd. (UK) (“MacDermid Autotype”) have taken several important steps to combat slavery and human trafficking. However, we recognize this is an ongoing process, and additional work can be done to improve our practices constantly and we will endeavour to do so. MacDermid Autotype is committed to ensuring its supply chain is free from slavery and human trafficking.
• Organisation’s structure
MacDermid Autotype innovates, formulates, and manufactures high-quality precision-coated films and blended liquids for use in the automotive, electronics, and printing industries. MacDermid Autotype is part of Element Solutions Inc (hereinafter “Element Solutions”). Element Solutions’ head office is in the USA. It has approximately 5.300 employees worldwide and a global annual turnover of approximately US$2.5 billion.
• Our supply chains
The MacDermid Autotype supply chain utilizes a global supply base. These suppliers deliver raw materials and 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. Element Solutions has also instituted a global Supplier Code of Conduct, which mandates various social compliance requirements, including prohibiting using slave labor in our supply chain. Element Solutions makes its Supplier Code available on its website, and it expects its and its subsidiaries’ suppliers to comply with it. MacDermid Autotype also selectively audits suppliers to help ensure compliance.
• 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 a 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 are not taking place anywhere in the supply chains worldwide.
MacDermid Autotype’s Anti-slavery and Human Trafficking Policy is available on request.
Additionally, employees and contractors must abide by Element Solutions’ 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. These documents can be found on Element Solutions’ website.
• 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 surveys the anti-slavery and human trafficking compliance programs and policies of new suppliers that it onboards. 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 currently satisfied that its suppliers have devoted sufficient attention and resources to this important issue.
Element Solutions worldwide quality organization also monitors the supply base. This includes auditing suppliers when concerns arise regarding their adherence to requirements. For example, a detailed audit is performed if products are not meeting the applicable specifications. During such audits, a supplier’s social compliance efforts, including anti-slavery and human trafficking, will be reviewed under a standardized checklist. The quality organization performs similar audits of Element Solutions facilities.
Element Solutions’ Supplier Code of Conduct requires suppliers to have policies and procedures so that employees can raise concerns without fear of reprisal. The policy explicitly prohibits retaliation against whistle-blowers.
• Supplier adherence to our values
MacDermid Autotype has zero tolerance for slavery and human trafficking. MacDermid Autotype has a supply chain compliance program designed to ensure all those in the supply chain and contractors comply with these values. This consists of:
• Pre-contract screening: As part of standard practice, all potential suppliers and 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 worldwide. These lists track companies and individuals who are believed to be terrorists, drug traffickers, or have committed human rights violations.
• Supplier Survey: MacDermid Autotype surveys its new suppliers, assessing their policies
and procedures regarding anti-slavery and human trafficking. Based upon the results of these surveys, MacDermid Autotype is satisfied by the efforts of its supply chain but recognizes the importance of having up-to-date information and is prepared to carry out repeat surveys on suppliers when the situation so requires (e.g., where MacDermid has concerns relating to that supplier).
• Quality Department Audits: Element Solutions global quality department audits suppliers. These audits are performed on suppliers who do not meet Element Solutions requirements. Anti-slavery and human trafficking compliance is an integral part of the audits.
• Supplier Code of Conduct: Element Solutions has instituted a worldwide Supplier Code of
Conduct. This Code of Conduct prohibits the use of any slave, forced, trafficked, involuntary prison, or indentured (including debt-bonded) labor in the supply chain. This Supplier Code of Conduct is available on Element Solutions’ website, and Element Solutions’ and its subsidiaries’ suppliers are expected to comply with it.
This statement is made under section 54(1) of the Modern Slavery Act 2015 and constitutes MacDermid Autotype’s slavery and human trafficking statement for the financial year ending 31st December 2023.
• Operations
• Procurement/Sourcing
• Quality
• Compliance
• Business Unit Management
• Legal
• Human Resources
• Training
Employees are trained on business ethics and Element Solutions’ Business Conduct and Ethics Policy, including the risks of modern slavery and human trafficking in the supply chain and to the business.
Future efforts will include training suppliers we identify as high risk about the Supplier Code of Conduct. High-risk suppliers will also be required to provide training to their employees relating to the recognition and prevention of slavery and human trafficking.
• Effectiveness in combating slavery and human trafficking
MacDermid Autotype has implemented a new rating system (scorecard) for suppliers, including 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 determine if remedial action needs to be taken. Because of the zero-tolerance policy, MacDermid Autotype reserves the right to terminate business relationships if a supplier is found to be using forced, trafficked, or slave labor.
This statement is made under section 54(1) of the Modern Slavery Act 2015 and constitutes MacDermid Autotype’s slavery and human trafficking statement for the financial year ending 31st December 2022.
Statutory Director MacDermid Autotype Ltd
