Slavery And Human Trafficking Statement

The Modern Slavery Act

This statement is made on behalf of the LIBERTY Steel Group (LSG) pursuant to section 54 of the Modern Slavery Act 2015 (the Act) and constitutes our slavery and human trafficking statement and is intended to demonstrate how GFG applies its values in the course of business and highlights the degree to which we view our duty to challenge and confront the use of forced, compulsory, trafficked or child labour within our own organisation and our supply chains.

Our principles, policies and code of conduct in respect of combatting slavery and human trafficking

In this world of limited resources, rising population and cycles of prosperity and recession, we need a new model for industry and a smarter way of using resources. LSG has a vision which sees a more sustainable and non-cyclical future for industry as a foundation for a stronger and more prosperous society.

LSG’s mission is to re-establish the pivotal position of metals manufacturing and engineering in the geographical markets where it operates through using local resources, sustainable energy, investment, technology and skills.

Its strategy for delivery uses its extensive industrial, commodity and financial resources that work together to achieve an outcome that is larger than the sum of its parts.

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our human rights policy 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 slavery and human trafficking are not taking place any where in our supply chains.

LSG aspires to play an important role in the fight against the existence of slavery and human trafficking within the sectors in which we operate. We are keenly aware of the adverse impacts such practices have on the lives of vulnerable individuals. In the spirit of our GREENSTEEL philosophy which is based on sustainability and respect, we feel we have a particular duty to take a lead in upholding human rights through our business practice.

We have zero tolerance of slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have put in place a number of human rights focused policies.

Our policies

Human rights
In 2018, LSG introduced a human rights policy that demonstrates our commitment to combatting human rights abuses and modern slavery, encompassing internationally-recognised human rights such as those laid out in the International Bill of Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work, and illustrates how we expect to operate across LSG. Our human rights policy also sets out our intention to implement the UN Guiding Principles on Business and Human Rights in all areas of our business and to continually monitor LSG’s impact on human rights.

LSG’s human rights policy focuses on the core sectors of our business where we intend to be particularly mindful of our impact on human rights. In our capacity:

  • as a goods and services provider we are committed to ensuring that human rights considerations are reflected in our systems, processes and controls throughout the period of engagement with our customers and cycle of our supply chain; and we will work with our clients and suppliers to increase their respect for and understanding of human rights as well as of their potential adverse impacts;
  • as a purchaser of services, materials and products we are committed to engaging suppliers who respect human rights and whose principles align with our own; and to working in cooperation with our suppliers to broaden their understanding of human rights and to ensure their commitment to respecting human rights; and
  • as a global business: we are committed to treating all of our employees fairly, and without discrimination, whilst providing safe working conditions which respect their human rights. We are also opposed to any form of forced, compulsory, trafficked or child labour in either our own business or that of our supply chains.

The human rights policy encourages all employees to raise any concerns, questions or grievances, and requires them to report any known or suspected violations of applicable laws, regulations, policies or ethics. Any concerns related to human rights internally or in our supply chain including forced compulsory, trafficked or child labour is to be reported in accordance with our whistleblowing policy.

Whistle-blowing
In support of the human rights policy, LSG has also introduced a whistle-blowing policy to allow potential breaches of human rights and modern slavery concerns to be escalated and handled in a confidential and sensitive manner.

Suppliers and vendors
Prior to engaging with third party vendors or suppliers, we endeavour to screen for human rights breaches as part of our onboarding process.

LSG has produced a supplier charter, which-stipulates the standards expected of our suppliers, providing them with a principle-based approach on how we expect them to conduct business within both their own operations and within their own supply chains.

The supplier charter has five main tenets and requires that all of our suppliers should:

  • not hold another person in any form of slavery, or employ, engage or otherwise use forced, compulsory or child labour, as well as reframing from using any abusive or inhumane treatment of any of their employees;
  • not act, or fail to act, in such a way that they would directly or indirectly adversely impact the human rights of any individual or third party;
  • comply with all applicable employment and diversity laws, including with regard to recruitment, retention and promotion of employees;
  • comply with all health and safety laws and provide a safe working environment for all employees; and
  • report any breach of the supplier charter and to take reasonable steps to redress, remedy and prevent any further breaches of the supplier charter.
KPIs

The implementation of our human rights policy, supplier charter, whistle blowing policy, external vendor and supplier onboarding policy are the 2018 steps taken as part of our mission to, create a series of underlying principles, systems and processes to systematically address modern slavery throughout LSG and our supply chains.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we endeavour to provide training to our staff. LSG recognises that the knowledge, responsibility and conduct of our staff play an important role in mitigating the risk of slavery and human trafficking within our organisation.

Approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes LSG’s slavery and human trafficking statement for the financial year ending 2017.