Modern Slavery and Human Trafficking

February 2023

This Modern Slavery & Human Trafficking Statement is in response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 2022/23.

Sherwood Stainless and Aluminium Limited, is committed to preventing slavery & human trafficking violations in its own operations, its supply chain, and its products. We have a zero-tolerance towards, slavery and require our supply chain to comply with our values.

Organisational Structure

Sherwood Stainless and Aluminium Limited is the parent company of the Sherwood Group and has the following business operations INAL 2020 Limited, Neville’s Precision Engineering Limited and UB Plastics Limited, which are all based in the United Kingdom.

We operate in the metals & plastic injection.mouldings sector. The nature of our supply chains is as follows: aluminium extrusions, stainless steel flat rolled, aluminium flat rolled & plastic injection mouldings.

Policies

We operate several internal policies to ensure that we are conducting business in an ethical and transparent manner.

These include the following:

• Recruitment & Selection policy – We conduct checks on all prospective employees to verify that they are eligible to work in the UK.
• Supplier Code of Conduct – We operate this policy to ensure our suppliers operate in full compliance with the laws, rules, and regulations of the countries in which they operate, and to seek similar commitments across their own supply chain.
• Whistleblowing Policy – We operate this policy so that employees are able to raise concerns about how employees are being treated or practices within our business or our supply chains without fear of reprisal.
• Fair Treatment Policy – We are committed to the fair treatment of all our employees. This policy reflects our core values and expected behaviours of all employees. This policy makes it clear that we have a zero-tolerance approach to modem slavery.
• Responsible Sourcing Policy – We want to ensure that all potential suppliers are committed to ensuring that slavery and human trafficking is not taking place within their own supply chains. Our Responsible Sourcing Policy and supporting procedures sets out controls and checks undertaken to help verify this.

We make sure our suppliers are aware of our policies and that they adhere to the same standards.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:

• Internal Supplier audits
• External Supplier audits
• Checking certain suppliers with external third parties for any slavery or human trafficking risks

Our due diligence procedures aim to:

• Identify and action potential risks in our business and supply chains
• Monitor potential risks in our business and supply chains
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains
• Provide protection for whistle blowers.

Risk and Compliance

The company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK/EU supply chain through:

• Evaluating the slavery and human trafficking risks of each new supplier
• Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping

We do not consider that we operate in a high-risk environment in the UK/EU.

The company has also evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its Far East supply chain using the same methodology and consider that we operate in a higher- risk environment to that of the UK/EU supply chain.

The majority of the supply chain is based in Europe.

We do not tolerate slavery or human trafficking in our supply chain. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will require the supplier to correct the non-compliance, or we will remove them from our supply chain.

Effectiveness

The company uses Key Performance Indicators (KPl’S) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPl’s are as follows:

• We will contact suppliers to enquire about their modem slavery practices every 12 months
• We will train our staff about modem slavery issues and increase awareness within the company
• We will carry out a regular audit of suppliers, 100% of suppliers each year.

Training our employees

The Company requires its employees to complete training and ongoing refresher courses on slavery and human trafficking. The Company’s training covers:.

• What initial steps should be taken if slavery or human trafficking is suspected
• How to escalate potential slavery or human trafficking issues to relevant parties within the Company
• What external help is available

The Statement was approved by the Board of Directors

Paul Thurston Chairman

Terry Franklin Managing Director

Sherwood Stainless & Aluminium Limited 15^th February 2023

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