MODERN SLAVERY STATEMENT (the “Statement”)

MEXICHEM UK LIMITED

This Statement is published in accordance with section 54(1) of the Modern Slavery Act 2015 (“MSA) and sets out the actions that Mexichem UK Limited (“Mexichem UK”) has taken during the financial year ended 31 December 2023 to address modern slavery. It also outlines the steps that Mexichem UK will continue to take to identify, prevent and, where found, eliminate modern slavery in its business and supply chains.

Introduction

Modern Slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Victims are coerced, deceived and forced against their free will into providing work or services. Modern slavery is a crime and a violation of fundamental human rights and Mexichem UK recognizes that this is a global issue taking many forms and affecting many industries and sectors. Mexichem UK acknowledges its responsibilities in respect of anti-slavery and human trafficking and is committed to improving its practices to combat slavery and human trafficking.

Organisation’s structure

Mexichem UK is a subsidiary of Mexichem Fluor, S.A. de C.V. The Mexichem business is a global leader in the development, manufacture and supply of fluoroproducts that play a fundamental role in enhancing everyday lives. We are the largest producer of fluorspar in the world, and our products are used within our manufacturing centres to produce refrigerants and medical grade hydrofluoric acid for use in the pharmaceutical sector. Our products are sold in over 50 countries around the world.

We are a part of the Orbia Group, a community of companies working together to tackle some of the world’s most complex challenges. The Orbia community is bound by a common purpose: To Advance Life Around the World. Our ultimate parent company is Orbia Advance Corporation, S.A.B. de C.V. (“Orbia”) which has its head office in Mexico. Orbia has over 24000 employees worldwide, with operations in 50 countries.

Mexichem UK currently employs 228 people and has 3 operating sites at:

• Thornton Science Park, Pool Lane, Ince, Cheshire CH2 4NU.
• The Heath Business & Technical Park, Runcorn, Cheshire WA7 4QX; and
• Rocksavage, Runcorn WA7 4JE.

Mexichem UK has an annual turnover of £74 million. Manufacturing, Service Delivery, Finance, Commercial and Growth and Technology functions are located in the UK.

The team in Mexichem UK works with colleagues in the UK, US, Mexico and Japan, which are four countries where the wider Mexichem business has operations globally, plus colleagues in Asia, Europe, India, Mexico amd Latin America.

Our supply chains

Mexichem UK’s supply chain includes circa 500 suppliers actively supplying goods and services to Mexichem UK from across 25 countries globally, from regions including Europe, India, Middle East, North America and Asia Pacific.

Categories of supply include Raw Materials, Packaging, Industrial Equipment, Professional Services, HR Services, Logistics Services, IT Goods and Services and Workplace Services.

We deliver a range of finished products to our customers worldwide, interacting with organisations across Europe, India, Middle East, North America, South America and Asia Pacific. Finished product is delivered in a variety of packages, including Isotanks containing circa 19T and smaller cylinders ranging in size from 10kg cylinders up to 1 Tonne. A variety of transportation is used including rail, road and ship.

 Our policies on slavery and human trafficking

Orbia has a strict policy prohibiting any form of modern slavery or human trafficking in our supply chains or in any part of our business and has made those expectations clear to its suppliers. In May 2023, Orbia held its annual Ethics Month events, in which colleagues are required to complete online Code of Ethics training and invited to attend a webcast with the global Ethics & Compliance team. The 2023 online training module, like the 2022 course, reinforces Orbia’s prohibition of modern slavery contained in its Code of Ethics, and the course has a dedicated discussion of this important topic.

Orbia also has publicly available global policies, including a Human Rights Policy (Human Rights Policy | Orbia) and Anti-Slavery & Human Trafficking Policy (Anti-Slavery & Human Trafficking | Orbia), all of which apply to Mexichem UK and which address this topic. These policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. Orbia’s 2023 Sustainability Report additionally makes clear that Orbia is committed to ensuring that its supply chain complies with human rights and modern slavery laws.

Orbia has policies in place to encourage individuals to submit reports of suspected violations of our Code of Ethics, as well as to ask for guidance related to policies and procedures. Orbia administers an Ethics Helpline, which is available 24 hours a day, 7 days a week, in all the languages of the countries where Orbia does business. The Ethics Helpline is available for anonymous reporting, and can be accessed by third parties, including Orbia’s and Mexichem UK’s suppliers and business partners by visiting its webpage at www.orbia.com. All reports are fully reviewed, investigated, and the appropriate action taken as a result. Orbia’s 2023 Sustainability Report details more information about the Ethics Helpline, including the fact that we received and addressed 374 matters in 2023.

Orbia’s policies are developed by subject matter experts and are signed off at the Vice President level. As part of the Orbia family, Mexichem UK benefits from having a consistent global approach to these policies. We believe that it is important to review these policies periodically to ensure they meet evolving requirements, and the Anti-Slavery & Human Trafficking Policy was reviewed in January 2022 and is slated for an update in 2024.

Finally, sourcing of goods and service is governed by Mexichem UK’s Procurement Policy, which requires all such activities to be undertaken in accordance with our Code of Ethics, which explicitly applies to our suppliers. In December 2023, Orbia published its Suppliers Code of conduct, which sets forth Orbia’s expectations on a variety of topic as, including that suppliers will have processes in place to meet applicable labor and human rights laws.

Due diligence processes for slavery and human trafficking

We believe our biggest exposure to Modern Slavery to be within the supply base, rather than our own internal recruitment process.

We have taken steps to mitigate both our internal recruiting risk and that within our supply chain. For example, we currently undertake due diligence within our own recruitment process, completing identity and right to work checks. On the supplier selection and approval front, we undertake due diligence during the onboarding process of suppliers. We have actively reviewed our supplier on-boarding procedure to ensure that it is robust and fit for purpose.

Our standard supplier contract terms and conditions include obligations on our suppliers to comply with all applicable laws, statutes and regulations (which would include the Modern Slavery Act 2015) as well as compliance with Orbia’s Code of Ethics. Failure to comply with these provisions gives us the ability to terminate agreement with that supplier.

We also have in place systems to protect whistleblowers and in May 2023, we refreshed Orbia’s Speak Up, Investigations and Non-Retaliation Policy. This Policy makes clear that anyone who raises a concern in good faith, including suppliers, are protected under Orbia’s non-retaliation policy. We also make Orbia’s Ethics Helpline publicly available on Orbia’s website, which means Orbia’s business partners or other third parties can report violations of the law, including making an anonymous report.

Orbia continues its implementation of EcoVadis (a well-respected supply chain sustainability management platform) throughout the company to support us in the ongoing compliance monitoring of our supply chains and to identify suppliers that may have gaps or significant risks. Ecovadis’ supplier assessments cover 4 areas: Labour & Human Rights (including modern slavery), Ethics, Environment, and Sustainable Procurement. Supplier performance in these areas is assessed, including identification of risk areas, enabling us to implement corrective action plans for high-risk suppliers. Mexichem UK adopted the use of the Ecovadis program in 2021, which is enhancing its Modern Slavery compliance program protocols. Mexichem UK will continue to expand the EcoVadis program across our suppliers and incorporate it into our Procurement processes.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to all employees with access to computers (which is all UK employees). All such employees are required to complete an online Code of Ethics training module annually during Ethics Month, which typically takes place in the spring. The importance of compliance with child labor and modern slavery norms has been covered in the June 2020, May 2021 May 2022 and May 2023 courses, and over 99.8% of eligible employees completed the course by the required deadline. Our May 2024 Code of Ethics course again underscored the importance of ensuring compliance with child labor and modern slavery legislation in our supply chain.

Our effectiveness in combating slavery and human trafficking

Modern Slavery risk is fluid, and our approach must continue to evolve to meet the risk. To ensure we are taking a programmatic approach to address this important risk, in 2022 Orbia officially appointed its Chief Compliance Officer to lead its Anti-Modern Slavery program. In 2023, Orbia staff members participated in the United Nation’s Business & Human Rights Accelerator Program, which is a six-month training program focused on building effective human rights programs. In addition, this year we continue to leverage the EcoVadis tool within our supply base and to monitor our supply chain via a risk assessment process, as well as continue educate our workforce about the importance of speaking up if they see violations of our Code of Ethics, our policies and the law, including suspected violations of child labor and modern slavery laws.

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 31 December 2023. It was approved by the board on the date of signature below.

Valeria Barragan Villanueva, Director
Mexichem UK Limited
Date: October 1st, 2024