This statement is made pursuant to section 54(1) Part 6 of the UK Modern Slavery Act 2015 and constitutes the Paralloy Limited Statemen on Modern Slavery.

Our Organisation:

We manufacture centrifugally cast products and solutions to the power generation, transportation, manufacturing, and critical chemical industries. We both source materials and sell into markets across the globe. As such, we take a global approach to dealing with modern slavery.

Our Principles:

Paralloy Ltd and its suppliers are firmly committed at all times to being a responsible and ethical business and complying with the requirements of the UK Modern Slavery Act 2015 and the US Anti-Trafficking in Persons Act 2003 (‘Acts’).

We have zero tolerance for exploitation of any kind and understand that it comes in many forms, including human trafficking, forced labour, debt bondage/bonded labour, descent-based slavery, and child labour.

Our Policies:

We have implemented the following policies, procedures and agreements which form part of our approach to mitigate against the risk of modern slavery within our own companies or our supply chain:

  • Code of Ethics
  • Procurement Policy
  • Anti-Slavery Policy
  • Code of Practice for Diversity & Equality of Opportunity
  • Dignity at Work Policy
  • Grievance Policy and Procedure

Paralloy Limited may adopt such policies and procedures as deemed appropriate to the nature of our business and that of our supply chain partners. In keeping with our own high standards as an organization, we have elected to follow a proactive yet simple, common sense approach:

  • Be aware: What is modern slavery and human trafficking? Take a moment to read about it here: Sadly, even today there are unscrupulous people who will take advantage of others who are disadvantaged. Just because a worker seems to have freedom of movement on the job does not mean they are not enslaved in the modern sense; language barriers or fear of abuse may prevent a person from helping themselves escape an abusive situation.
  • Keep alert: Everyone should keep alert internally and when dealing with suppliers. Many of us will have the opportunity to make observations when visiting a supplier’s premises. More frequently all of us come into contact with service providers such as cleaning services and other contractors who attend our premises.
  • Accept no excuses: Never look the other way for the sake of convenience or short‐term profit considerations. If taking action causes inconvenience or additional expense, do it. You will be rewarded for doing the right thing.
  • Report any concern: Do not hesitate to report any concern at once directly to myself or Ian Grimes HR Manager or any company director.

Due Diligence Processes:

We recognise that slavery has been linked to certain raw materials commonly used in our industry, such as nickel and cobalt mining. We are working hard to ensure that materials linked to exploitation do not enter our supply chain.

Consistent with the requirements of the Acts, we have implemented the following compliance procedures:

  • Risk assess all current suppliers (global and domestic) and seek positive confirmation, assurances and written undertaking from all ‘material’ suppliers of their compliance with the Act.
  • Amend, update and change supplier contracts requiring suppliers’ compliance with the Act either at contract renewal, during the course of the contract or at engagement.
  • Risk assess all new suppliers.
  • Seek to replace suppliers who fail to provide adequate evidence, assurance and undertaking that they comply with the requirements of the Act.
  • Implement a robust on-going due diligence and audit process in relation to slavery and trafficking in the supply chain.
  • Provide appropriate training, training material and information to applicable employees, consultants, sub-contractors, agents and suppliers, to ensure awareness and compliance with the Act.

Awareness and training:

Raising awareness and training is a key focus for us. Our employees are trained to recognise and report any suspicions they have on modern slavery.

We ensure that as part of the onboarding process all employees are made aware of our Code of Ethics, the Paralloy Limited Statemen on Modern Slavery and supporting policies.

We provide appropriate training, training material and information to applicable employees, consultants, sub-contractors, agents and suppliers, to ensure awareness and compliance with the Act.

Implementation and Audit:

The Company will ensure the following (which is not an exhaustive list):

  • All employees are paid the national minimum wage or above.
  • All employees working conditions are to the national working standards or above.
  • All employees working hours are to the national maximum working hours.
  • Ensuring non-exploitation of individuals who are not legally entitled to employment.
  • Ensuring the non-use and non-exploitation of child labour – all employees are above the national minimum working age.
  • Ensuring there is no forced labour (including human trafficking) or any form of physical disciplinary abuse.
  • Ensuring each site is adhering to employment laws and regulations and the Paralloy Code of Conduct.
  • Ensuring all suppliers provide adequate evidence, assurance and undertaking that they comply with the requirements of the Act.
  • All employees and supplier are provided with relevant training and material and monitoring the effectiveness of such training.
  • Ensure standard terms and conditions of Sale and Purchase to include clauses which forbid the use of forced labour, child labour and physically abusive disciplinary practices.

Monitoring and Oversight:

Board of Directors has overall responsibility for ensuring that this statement complies with our legal and ethical obligations and that it is reviewed on an annual basis, be publicly available and signed by the CEO.

The Executive is responsible for raising awareness and implementing the policies supporting this statement.

The devolved procurement teams and the Internal Audit function have responsibility for implementing this policy statement and monitoring its effectiveness across the business

For and behalf of the Paralloy Limited Board of Directors

Robert McGowan

Chief Executive Officer