Modern slavery policy

In accordance with the Modern Slavery Act 2015, Tri-Wall UK Limited (“Tri-Wall”) is committed to a work environment that is free from human trafficking, forced labour and unlawful child labour (collectively “human trafficking and slavery”). It also strongly believes that it has a responsibility for promoting ethical and lawful employment practices.

Accordingly, Tri-Wall will not knowingly use unlawful child labour or forced labour in any of the utilities and/or other commodities, products and/or services it provides, nor will it accept commodities, products and/or services from suppliers that employ or utilize child labour or forced labour.

About us

We are a manufacturer of corrugated fibre board and timber packaging in FMCG and heavy industrial sectors, including automotive, aerospace, military and many others. We are a part of the Tri-Wall Limited Group. TriWall Limited Group has its head office in Hong Kong and have over 1,900 employees worldwide, operating in Europe, China, Japan, South East Asia, India and the Middle East.

Tri-Wall UK is organised into six business sites:

Tri-Wall Chesterfield: corrugated fibreboard packaging

Tri-Wall North East: corrugated fibreboard packaging and timber packaging

Tri-Wall Monmouth: corrugated fibreboard sheet and packaging

Tri-Wall Swansea: corrugated fibreboard packaging and timber packaging

Tri-Wall Valenbeck: timber packaging

Tri-Wall West Midlands: corrugated fibreboard packaging and timber packaging

Our supply chains include:

Suppliers: Companies or individuals providing raw materials, components, or finished products.

Logistics Providers: Companies responsible for transporting goods from our manufacturing sites.

Subcontractors: Any third-party companies that perform specific tasks or services within the supply chain.

Rationale

Human trafficking and slavery are crimes under UK and international law. These crimes exist in countries throughout the world. This policy statement thus defines Tri-Wall’s commitment to ensuring that human trafficking and slavery does not exist within its own business, but also provides how Tri-Wall will make efforts to eradicate the same from other businesses with whom it shall maintain a relationship (and especially from within its supply chain).

Tri-Wall has appointed its HR Officer as its compliance officer (its Anti- Slavery and Human Trafficking Officer) and will take appropriate steps to ensure not only its own compliance but also that these requirements are followed by its suppliers, subcontractors and/or business partners (collectively by its “Suppliers”) worldwide. We continuously review and update all our policies.

All Supplies are therefore required to adhere to the following:

Definitions

“Human Trafficking”: means the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.

“Forced Labour”: means all work or service, not voluntarily performed, that is obtained from an individual under the threat of force or penalty.

“Harmful Child Labour”: means consists of the employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral, or social development.

Requirements for Suppliers:

We have a zero tolerance to slavery and human trafficking. All our supply chain must comply with our values, as set out below:

Will not use forced or compulsory labour, i.e., any work or service that a worker performs involuntarily, under threat of penalty;

Will ensure that the overall terms of employment are voluntary;

Will comply with the minimum age requirements prescribed by applicable laws;

Will compensate its workers with wages and benefits that meet or exceed the legally required minimum and will comply with overtime pay requirements;

Will abide by applicable law concerning the maximum hours of daily labour;

Will not engage in any practice of slavery, servitude, forced labour, compulsory labour and/or human trafficking outside the UK which would constitute an offence if that conduct took place within the UK; and,

Will ensure that any sub-contractors or suppliers from whom they source goods and/or services for incorporation in those supplied to Tri-Wall, also adhere to these requirements.

Training:

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chain and our business, we provide training to our staff.

Certification:

Suppliers will certify compliance with this Policy and their adherence to relevant human trafficking and slavery laws in each of the relevant countries in which they operate.

Audits:

Upon request, Suppliers must be able to demonstrate compliance with this Policy to the reasonable satisfaction of Tri-Wall. Tri-Wall may perform periodic audits on this Policy and Suppliers are expected to fully co-operate with any such audit.

Reporting:

Any breach of this Policy (including by a Supplier) can be reported (in confidence, if required) by contacting Tri-Wall’s HR Officer (in the capacity of Tri-Wall’s Anti-Slavery and Human Trafficking Officer).

Consequences:

Tri-Wall takes any breach of this Policy extremely seriously.

Suppliers who are found to have or be engaging in human trafficking and slavery or which refuse to cooperate with any audit to verify compliance with this Policy will be liable to have any supply agreement, arrangement or other contract with Tri-Wall terminated immediately, without compensation.

If a Supplier to Tri-Wall is found in violation of this policy, Tri-Wall will take prompt action which may include terminating any supply agreement, arrangement or other contract with that Supplier (as above). It shall also take such other (remedial) steps as the Anti-Slavery and Human Trafficking Officer shall determine to be necessary to address the violation and seek to prevent its reoccurrence.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2024.

It was approved by the Board on 26th September 2024.