Innovative Solutions in Material Technology

Innovative Solutions in Material Technology

Modern Slavery Act Statement

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps taken by Luxfer and its subsidiaries ("Luxfer Group"), for financial year ending December 31, 2016.

To ensure that slavery and human trafficking is not operating within any of the Luxfer Group’s businesses or supply chains.

Introduction

Luxfer is aware that modern slavery takes various forms, including slavery, servitude, forced labour, child labour and human trafficking, and that it is a global and growing issue. Luxfer has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all of its business dealings and relationships. Luxfer encourages all stakeholders in its businesses to bring to its attention issues or grievances relating to any potential human rights concerns.

Organisational Structure

Luxfer is a global materials technology company, specialising 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 Salford, UK, the Luxfer Group has a global presence employing over 1,800 staff and operating from 20 manufacturing plants based in the US, UK, Canada, France, the Czech Republic and China. In 2016 our total revenue was in excess of approximately $415 million.

The Luxfer Group is organised into two reporting divisions:

  • Elektron – specialising in the design and manufacture of lightweight magnesium alloys, powders and plates as well as a range of specialty zirconium chemicals.
  • Gas Cylinders – specialising 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

The Luxfer Group 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 Group employees but also available to others working in the Luxfer Group’s 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

Businesses within the Luxfer Group 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 the Luxfer Group 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 within the Luxfer Group to ensure a high level of awareness and understanding of the risks and implications of modern slavery in all areas of the Luxfer Group and its supply chains.