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Modern Slavery Act 2015

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps taken by Luxfer Holdings PLC and its subsidiaries (“Luxfer”), for financial year ending December 31, 2016, to ensure that slavery and human trafficking is not operating within any of Luxfer’s businesses or supply chains.

Organizational structure

Luxfer is a global materials technology company, specializing in the design, manufacture and supply of high-performance materials, components and high-pressure gas-containment devices for healthcare, environmental, protection and speciality end-markets. Headquartered in Manchester, UK, Luxfer has a global presence employing over 1,700 staff in 27 countries and operating 20 manufacturing plants in 7 countries. In 2017 our total revenue was approximately $441 million.

Luxfer is organized into two reporting divisions:

  • Elektron – specializing in the design and manufacture of lightweight magnesium alloys, powders and plates as well as a range of specialty zirconium chemicals.
  • Gas Cylinders – specializing in the development and manufacture of high-pressure aluminium and composite cylinders, systems and accessories as well as a lightweight aluminium panels, superformed into highly complex shapes.

Supply chain

Luxfer has a very broad-based and complex supply chain, which includes the sourcing of primary magnesium, aluminium log and alloys, zirconium sand, rare earth metals, carbon fibre and other speciality chemical compounds and intermediaries. Luxfer is aware that multiple risks accompany such a complex supply chain, including the possibility that modern slavery may be taking place.

Relevant policies

Luxfer’s internal policies include:

  • a code of ethics and business conduct, which sets out Luxfer’s principles, requirements and expectations in relation to the protection of human rights in all areas of its business; and
  • a whistleblowing policy, aimed principally at Luxfer employees but also available to others working in the Luxfer supply chains, which encourages the reporting of any wrongdoing which potentially involves human rights violations, including modern slavery. All reports will be fully investigated and remedial actions taken as appropriate.

Due diligence and audit of suppliers

Luxfer businesses operate a supplier selection process and have considerable knowledge and understanding of many of the major suppliers, with whom they have a close, long standing business relationship. While Luxfer sources a significant portion of its material and services from European and North American based suppliers, it is understood that some of the goods and services that are purchased, and the countries from which they are sourced, may carry a greater risk.

As part of Luxfer’s ongoing commitment to identify and mitigate the risk of modern slavery in its supply chains, the following steps will be taken:

  • audits of new and existing suppliers and manufacturing sites by Luxfer staff;review and update of contractual terms with suppliers to ensure they include prohibitions on modern slavery; and
  • continued protection of whistleblowers in accordance with the Luxfer Whistleblowing Policy.

Training

Luxfer will provide appropriate training to employees to ensure a high level of awareness and understanding of the risks and implications of modern slavery in all areas of the Luxfer businesses and their supply chains.

 

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