Modern Slavery Disclosure Statement

Revision Date: May 22, 2023

Aurorium has issued this statement in accordance with the United Kingdom Modern Slavery Act of 2015 to describe various steps taken to avoid and combat any form of slavery or human trafficking in our supply chain.

Aurorium Overview and Supply Chain Structure

Aurorium is a leading provider of specialty chemicals for the agriculture, nutrition, fine chemicals, pharmaceutical and medical, personal care, plastics, coatings, and industrial markets with more than 900 employees in 15 locations.

As a global group with manufacturing operations around the world, Aurorium relies on a vast network of suppliers. These supplier relationships are critical to our success. In keeping with our values, we have taken the steps outlined in the following sections to ensure that the suppliers we select and partner with meet our standards and adhere to our expectations for ethical conduct.

Commitment and Policy

At Aurorium we hold ourselves and each other accountable for delivering results with a bias for action while always acting with the utmost integrity. To support our values, deter wrongdoing, and to promote compliance with law, adherence to high ethical standards, and responsible business citizenship, we outline standards and expectations in our Code of Business Conduct, which is provided to every Aurorium employee. We respect the personal dignity of every human being and comply with all applicable human rights laws. With respect to our supply chain partners, we expect the same commitment to high ethical standards and compliance with applicable laws, including those relating to human trafficking and slavery. Aurorium has established an accountability framework relating to trafficking and slavery. This framework includes of our Code of Business Conduct and Supplier Code of Conduct.

Our Code of Business Conduct states:

We are committed to upholding fundamental human rights and believe that all human beings around the world should be treated with dignity, fairness, and respect. Our company will only engage suppliers and contractors who demonstrate a serious commitment to the health and safety of their workers and operate in compliance with human rights laws. Aurorium does not use or condone the use of child labor, slave labor, forced labor or human trafficking. Aurorium denounces any degrading treatment of individuals or unsafe working condition, and supports our products being free of conflict minerals.

Supplier Code of Conduct

The Aurorium Supplier Code of Conduct is distributed to all suppliers and incorporated in the terms and conditions of purchase with Aurorium suppliers. The Aurorium Supplier Code of Conduct outlines what Aurorium expects from our suppliers with respect to human rights, labor and employment rights, environmental health and safety, business ethics and social responsibility, and global trade practices. Suppliers are expected to adhere to this code and must operate in full compliance with the laws and regulations of the countries they operate. Failure to comply with internationally recognized standards, and the standards set forth in this document, may result in the termination of the supplier’s contract. Amongst other things, the Supplier Code of Conduct requires:

Employment Is Freely Chosen

There is no forced, bonded or involuntary prison labor.
Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice.

Freedom of Association and the Right to Collective Bargaining Are Respected

Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
Suppliers will respect employees’ lawful right of free association and to join, form, or not join a labor union or otherwise engage in collective bargaining.
Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace.Working conditions are safe and hygienic.
A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimizing, so far as is reasonably practicable, the causes of hazards inherent in the working environment.
Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.
Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.
Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.
The employer shall assign responsibility for health and safety to a senior management representative.

Child Labor

The terms of engagement, conditions of work and the minimum age of workers should be consistent with national laws and regulations for the type of labor and working conditions in the supplier’s facilities.

Legal Wages Are Paid

Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards.
All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.
Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

Risk Assessment

Aurorium is evaluating the nature and extent of our exposure to the risk of modern slavery occurring in our supply chain. We will consider information received from suppliers. Risk will be assessed using many factors and is then used as an input to both the due diligence and audit evaluation processes.

Due Diligence and Audits

Should risk be deemed elevated for suppliers, a targeted due diligence process will be performed and required actions will be defined.

Accountability and Effectiveness

Aurorium encourages an open environment where concerns can be raised, and people feel confident to speak up. Multiple channels are provided to employees to speak up including a 24/7 hotline with local language support and an on-line form version.

Training

Our procurement process is communicated to members of staff who have responsibility for supplier relationships. Our procurement processes incorporate our approach to forced labor. Training on responsible purchasing is will occur by year end 2021.

In addition, all Aurorium employees worldwide are required to complete annual training on the legal and ethical standards presented in our Code of Business Conduct.

Path Forward

Aurorium is committed to improving our understanding and management of modern slavery risks over time. As we learn from our risk assessments, we expect our approach to continue to evolve, our practices to become more refined and our capabilities to mitigate and support slavery and human trafficking risks to become more robust.