Introduction & Approval
This Anti-Modern Slavery, Child Labour, and Human Trafficking Statement (the “Statement”) is issued by Shotton Mill Limited pursuant to Section 54 of the Modern Slavery Act 2015. This Statement outlines the comprehensive steps taken and being taken to ensure that modern slavery, human trafficking, and the exploitation of child labour are not taking place within our business operations or our global supply chains.
Modern slavery and human trafficking are despicable crimes which have no place in society. At Shotton Mill Limited we acknowledge that unfortunately these crimes are still real-world occurrences and affect millions of people around the world, particularly in the developing world. We acknowledge that every company is at some risk of being involved, even if unknowingly, in this crime through its own operations and supply chain.
Shotton Mill Limited is committed to preventing modern slavery and human trafficking in all areas of our business and supply chains. We have a zero-tolerance approach to modern slavery, and we recognise our responsibility to operate ethically, transparently, responsibly and with integrity, and to implement effective systems and controls across all operations to ensure modern slavery is not taking place within our organisation or those we work with.
The Company adopts a risk-based approach, focusing its resources and controls on areas of higher risk within its operations and supply chains.
Board Approval and Publication: This Statement has been formally approved by the Board of Directors and is signed by a director. In compliance with the Act, a link to this Statement is published in a prominent location on the home page of the Shotton Mill Limited website.
Organisation Structure & Supply Chains
Shotton Mill Limited is a major participant in the manufacturing and paper processing sector, operating primarily from our site in Deeside, Flintshire and is committed to upholding ethical labour practices throughout our operations and supply chains. Our organisational structure emphasises fair treatment of all our employees at each stage of their employment, which is reflected in our people policies.
Shotton Mill Limited’s ambition when fully operational will be to produce high-quality products while maintaining strong ethical standards across all operations.
• Organisational Structure: Our business model is focused on industrial paper production. Our operations are generally consistent throughout the year and are not subject to significant seasonal labour fluctuations.
• Supply Chain Complexity: We acknowledge that the risk of modern slavery can be higher within supply chains. Whilst primarily engaging with suppliers in sectors generally considered low risk, we recognise that the potential for Modern Slavery activities is a risk in all supply chains. Therefore, we are proactively taking steps to ensure our procurement practices, and our suppliers are aligned with our commitment to human rights. Shotton Mill Limited is committed to working with suppliers who share our values and to promoting ethical practices. As part of our ongoing development, we are in the process of reviewing and strengthening our supplier due diligence procedures. Our supply chain involves the procurement of raw materials, chemicals, energy, machinery, and logistics services. We source goods and services globally.
• Stakeholder Relationships: We maintain professional relationships with all business partners, including trade unions and other bodies representing workers, to ensure a fair, safe, and transparent working environment.
Policies Relating to Modern Slavery, Child Labour & Human Trafficking
Shotton Mill Limited has established a zero-tolerance position on violations to the UK’s anti-human trafficking and anti-modern slavery laws. If we find breaches of these laws within our supply chain, we will look to support companies in their efforts to comply with the legislation.
Shotton Mill Limited does not view these efforts as a standalone requirement, but as an integral part of our corporate governance. We seek to treat everyone fairly and consistently, creating a workplace and business environment that is open, transparent and trusted. Our commitment to preventing modern slavery is supported by our internal policies, including our Code of Conduct, Recruitment and Human Resources practices, and Health and Safety standards. Our Employment policies protect our employees from unfair treatment and promote a fair and inclusive workplace and our wellbeing strategy and initiatives support our people’s physical and mental wellbeing and healthy lifestyle choices. We also recognise the importance of supplier engagement and are working towards strengthening our Supplier Code of Conduct and procurement processes.
Our commitment is reflected in the following policies:
• Anti-Slavery Policy: This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, and third-party representatives.
• Supplier Code of Conduct: We mandate that all suppliers and contractors comply with our anti-slavery, child labour, and human trafficking standards as a condition of doing business.
• Whistleblowing Policy: We encourage openness and accountability within our organisation. We are working towards strengthening formal reporting mechanisms, including whistleblowing processes, to ensure concerns can be raised safely and confidentially. Similarly to the practice within our Group companies in Turkey, the Company has established channels for employees and third parties to raise concerns, including confidential reporting routes. These arrangements are being further developed and enhanced to support anonymous reporting and strengthen accessibility.
• Recruitment and Procurement: Our processes are designed to ensure that all new hires and vendors are screened for compliance with fundamental human rights and legal labour standards.
This Statement should be read in conjunction with the Company’s Anti-Bribery & Corruption Policy and Third-Party Code of Conduct, which together form part of Shotton Mill Limited’s wider framework for ethical business conduct, supply chain integrity and compliance with applicable law.
Due Diligence & Risk Management
The implementation of our policies and procedures includes vendor due diligence in accordance with our procurement policy, we routinely assess the companies that we deal with as part of the decision-making process. When a new vendor is approved, a thorough due diligence process takes place to ensure that the vendor has a good reputation with appropriate credentials.
Shotton Mill Limited is currently developing and enhancing processes towards:
• Operations and Supply Chain Complexity: Better assess and manage modern slavery risks within our operations and supply chains.
• Supplier Vetting: Improve supplier evaluation and onboarding processes.
• Technology and Risk Monitoring: Introduce more formal risk-based checks where appropriate and to adopt an industry-recognised technology platform to monitor supply chain risks and gain visibility into the labour practices of our partners.
• Audits: Shotton Mill Limited reserves the right to perform routine audits of contractors and suppliers to verify compliance with this Statement.
• Remediation: If we suspect or identify evidence of exploitative practices, we reserve the right to suspend business relations, undertake investigations, and if evidence is confirmed terminate the relationship.
We recognise that tackling modern slavery requires continuous effort. Shotton Mill Limited is committed to reviewing and improving its policies, procedures, and controls over time to strengthen our approach.
Our due diligence processes are aligned with our Third-Party Code of Conduct and Anti-Bribery & Corruption Policy, ensuring a consistent, risk-based approach to supplier assessment, onboarding and ongoing monitoring.
During the reporting period, no confirmed instances of modern slavery were identified within the Company’s operations. Where concerns arise, they are investigated and addressed in line with Company policies.
International Standards & Frameworks
Our approach is aligned with global benchmarks for managing social and labour risks:
• International Finance Corporation Performance Standards: We align with Performance Standard 2 (Labour and Working Conditions), ensuring fair treatment, non-discrimination, and equal opportunity.
• Equator Principles 4: In accordance with the Equator Principles 4, we conduct human rights due diligence and maintain an accessible grievance mechanism to resolve concerns from workers and stakeholders.
• International Labour Organisation Conventions: Our policies are underpinned by the International Labour Organisation Declaration on Fundamental Principles and Rights at Work, including:
◦ The elimination of all forms of forced or compulsory labour.
◦ The effective abolition of child labour.
◦ The elimination of discrimination in respect of employment and occupation.
◦ Freedom of association and the effective recognition of the right to collective bargaining.
Specific Protections Against Child Labour
Shotton Mill Limited recognises the particular vulnerability of children to exploitation and the power imbalances that exist between adults and children. In accordance with International Labour Organisation conventions:
• Minimum Age: The Company does not employ individuals below the minimum legal working age in the relevant jurisdiction and applies additional safeguards for young workers in line with international standards.
• Hazardous Work: No persons under the age of 18 will be employed in work defined as hazardous by International Labour Organisation Convention Number 182 on the Worst Forms of Child Labour.
• Young Workers: Formal risk assessments are mandatory for all employees aged 16 to 18, and our Young Workers Policy stipulates that no person under the age of 18 will be employed for night work.
Training & Effectiveness
To ensure a high level of understanding of the risks of modern slavery and human trafficking, we provide ongoing capacity building:
• Mandatory Training: Shotton Mill Limited is working to increase awareness of modern slavery risks among employees. We are developing training and guidance to help staff recognise and report potential concerns. We are planning to conduct training sessions for employees at all levels, focusing on recognising the signs of modern slavery and human trafficking and the correct reporting procedures.
• Key Performance Indicators: We are working towards deploying systems to track and report on the following metrics to measure our effectiveness:
◦ The percentage of staff who have completed modern slavery and trafficking awareness training.
◦ The number of grievances or whistleblowing reports related to labour practices.
◦ The percentage of high-risk suppliers who have undergone formal due diligence or audits.
• Grievances and Complaints: A grievance register is in place to track issues arising from within our community. A community grievance registration process is available on our website and online grievance reporting is facilitated either by utilising the website or direct email. The number of grievances and response times are measured.
Compliance & Reporting
The prevention, detection, and reporting of modern slavery, child labour, or human trafficking in any part of our business or supply chain is the responsibility of all those working for us.
Employees are encouraged to raise concerns about any issue or suspicion at the earliest possible stage. Shotton Mill Limited aims to encourage openness and will support anyone who raises genuine concerns in good faith. We are committed to ensuring no one suffers any detrimental treatment including dismissal, disciplinary action, or threats connected with raising a concern.
Concerns may also be raised through the Company’s whistleblowing arrangements, which operate across all compliance areas including modern slavery, bribery and ethical conduct.
This Statement is reviewed annually and updated to reflect our ongoing commitment to human rights.
Hamdullah Eren Director, Shotton Mill Limited
Çiğdem Çekceoğlu Director, Shotton Mill Limited
Date: May 2026
Contact Information:Telephone: +44 (0)1244 280 000
Address: Weighbridge Road, Deeside Industrial Park, Deeside, Flintshire, CH5 2LW
Anti Modern Slavery Statement May 2026