Modern Slavery Statement

Modern Slavery and Human Trafficking Statement 2024/25

Introduction

This statement sets out Holme Dodsworth Metals Ltd's actions to understand all potential modern slavery risks related to its business and to implement measures to ensure there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year from 1st May 2024 to 30th April 2025.

As part of the metal stockholding industry, the organisation recognises its responsibility to take a robust approach to slavery and human trafficking. Holme Dodsworth Metals Ltd is fully committed to preventing slavery and human trafficking in its corporate activities and ensuring that its supply chains remain free from such practices.

Organisational Structure and Supply Chains

Holme Dodsworth Metals Ltd is a leading UK-based metal stockist, specialising in the distribution of semi-finished products, including brass, copper, copper nickel, stainless steel and aluminium alloy materials. The company supplies a wide range of industries, including power, precision engineering, undersea/marine and defence.

The company maintains a global supply chain, sourcing materials from reputable suppliers across Europe, Asia, and North America. This extensive network ensures the provision of high-quality materials while upholding ethical standards.

Countries of Operation and Supply

Holme Dodsworth Metals Ltd operates directly within the United Kingdom, with warehousing and distribution facilities located in 9 regions.

Our supply chain extends to countries including:

  • Germany
  • Italy
  • France
  • Netherlands
  • Denmark
  • Spain
  • New Zealand
  • Turkey
  • India
  • China
  • United States

We assess potential risks of modern slavery by evaluating country-specific human rights issues, supplier audits, and third-party compliance reports. Higher-risk countries are monitored more frequently, with additional due diligence measures applied.

High-Risk Activities

While our sector generally presents a lower risk of modern slavery, certain activities in our supply chain may be higher risk, particularly:

  • Sourcing of raw materials from regions with limited labour protections
  • Use of third-party contractors in logistics and transportation
  • Potential reliance on manual labour in manufacturing processes

These areas undergo enhanced scrutiny through desk audits, supplier assessments, and compliance checks.

Responsibility

Responsibility for anti-slavery initiatives is assigned as follows:

  • Policies: The Compliance Officer is responsible for policy development, review, and implementation.
  • Risk Assessments: The Compliance and Procurement teams conduct regular risk assessments to identify and mitigate modern slavery risks.
  • Due Diligence: Supplier onboarding and desk audits are overseen by the Procurement team in collaboration with third-party auditors.
  • Training: The Human Resources department delivers modern slavery training to relevant employees and contractors.

Relevant Policies

Holme Dodsworth Metals Ltd has implemented the following policies to prevent modern slavery:

  • Whistleblowing Policy: Employees and stakeholders are encouraged to report concerns through a confidential whistleblowing hotline.
  • Employee Code of Conduct: Employees are held to high ethical standards, including strict adherence to human rights principles.
  • Supplier Code of Conduct: Suppliers must commit to upholding ethical labour practices. Compliance is verified through audits and performance reviews.
  • Recruitment Policy: The company uses only reputable employment agencies and conducts checks to ensure fair recruitment practices.

Due Diligence

Holme Dodsworth Metals Ltd undertakes the following due diligence actions:

  • Supply chain mapping to assess risks
  • Pre-contractual supplier assessments
  • Regular supplier audits and performance monitoring
  • Collaborative engagement with suppliers to improve labour practices if required
  • Immediate termination of contracts where serious violations are identified

Performance Indicators

To monitor progress, the company tracks the following key performance indicators:

  • Completion of modern slavery training by all relevant staff
  • Percentage of suppliers audited for compliance
  • Number of reported incidents and resolutions
  • Supplier performance improvement metrics

Training

All supply chain managers, procurement staff, and HR professionals undergo mandatory modern slavery training. Training covers:

  • Risk identification and mitigation
  • Reporting mechanisms
  • Legal obligations under the Modern Slavery Act 2015
  • Best practices in supplier management

Awareness-Raising Programme

The company raises awareness through internal communications, including emails and presentations.

Employees are informed about how to spot signs of modern slavery and report concerns.

Board Approval

This statement was approved on 31/03/25 by the board of directors of Holme Dodsworth Metals Ltd and will be reviewed annually.

On behalf of

Holme Dodsworth Metals Ltd