Modern Slavery Statement

This statement, made pursuant to section 54(1) of the Modern Slavery Act 2015, sets out the approach taken by Verallia UK Limited to understand all potential modern slavery risks related to its business and the actions undertaken to mitigate any such risks during the financial year ended 31st December 2023.

We are committed to ensuring that as a business we take steps to minimise the risk of modern slavery in our business or supply chains and to acting ethically and with integrity in all our relationships.

Our Business

Part of the Verallia Group, who with 34 glass production plants in 12 countries, are the European leader and the world’s third largest producer of glass packaging for beverages and food products, Verallia UK Limited is a premium glass bottle manufacturer which designs, develops, manufactures and decorates luxury glass packaging.

Our glass packaging creations break the mould in more ways than one. We are prioritising the decarbonisation of our glass bottle manufacturing activities and looking to create sustainable glass packaging that would support a circular economy.

We have embarked on a journey to minimise our carbon and environmental footprint, investing in innovative technology and refining our processes to align with our Net Zero 2025 goal.

Verallia UK Limited has 610+ employees across 4 sites in West Yorkshire.

Group Code of Ethics

At Verallia we believe that respect for our values drives our business model and our stakeholders’ trust in us.

We undertake to promote sustainable, profitable growth that is respectful of the environment and our employees, partners, customers, suppliers, shareholders and investors. To that end, we

ask all our employees to embody our ethical principles on a daily basis and thus make Verallia an exemplary company.

Our Group Code of Ethics, which can be found on the Group website, aims to guide us on this path. It sets out our commitments and the behaviour we expect from all our employees. The rules it lays down apply to all of us, irrespective of our positions, across all levels of the Company.

Legal Compliance

Verallia UK Limited complies with the laws and regulations in force and our values are inspired by:-

• the Universal Declaration of Human Rights
• the principles of the International Labour Organisation

 

We adhere to the United Nations Global Compact and follow:-

• the OECD Guidelines for Multinational Enterprises
• the United Nations Guiding Principles on Business and Human Rights
• the International Human Rights Charter
• the regulations of all countries in which we operate, in particular regarding:
• the fight against corruption
• competition law
• respect for the environment
• work organisation

Some of the countries in which we operate may have stricter principles, practices or laws than those set out in the Group Code of Ethics. Regardless of the situation, everyone must comply with the most stringent rules.

The principles set out in the Group Code of Ethics also applies to our stakeholders, including suppliers, sub-contractors, sales representatives and other intermediaries and service providers.

Our Suppliers

Our manufacturing process includes significant volumes of materials and services, including energy, raw materials, moulds, consumables, packaging and logistics. As such we have a number of preferred suppliers for these materials and services, all of whom are expected to have noted our requirements under the Verallia Supplier Charter and have established similar arrangements in regard to our commitment to uphold ethical standards.

Verallia UK Limited applies the principles of honesty, integrity and fairness to its entire supplier panel and is committed to selecting its suppliers based on bidding processes that reflect real competition. Our Purchasing team use objective selection criteria (technical, quality, cost, service, social and environmental).

Suppliers that do not meet our ethical expectations will be excluded from the supplier panel.

Risk Management

Our Purchasing Department uses the Group supply chain risk management process to identify, anticipate, manage and mitigate risks. This process is aimed at selecting suppliers that are in line with Verallia UK Limited’s principles and fully engaging them in our corporate social responsibility (CSR) approach.

CSR criteria is included in purchasing procedures relating to call for tender in order to take into account the CSR approach taken by suppliers in the selection process. CSR clauses are also included in the contracts signed with suppliers.

In addition, Verallia UK Limited expects its suppliers to undergo CSR assessments, to participate in external audit campaigns and to be part of a continuous improvement process by implementing action plans.

Our Policies

Alongside the Verallia Code of Ethics, which clearly sets out our commitment to ethical practice that we expect all our employees and suppliers to work towards, Verallia UK Limited operates a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:-

• Recruitment Policy – we operate a robust Recruitment Policy, including conducting eligibility to work in the UK checks for all new employees to safeguard against human trafficking or individuals being forced to work against their will.

• Whistleblowing Policy – we operate a Whistleblowing Policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business, or supply chain, without fear of reprisals.

• Health & Safety Policy – our Health and Safety Policy outlines our commitment to maintaining a safe and healthy working environment and establishes the framework for managing risks and assigning responsibilities.

Verallia UK Limited’s policies will be continually reviewed and improved upon in light of any legislative changes and/or needs of the business.

Progress for the Financial Year Ending 31st December 2023

• During the last financial year we have successfully introduced the Verallia Group Supplier Charter, with 90% of suppliers signing up to the Charter (based on 2022 turnover).

The Charter helps identify and mitigate risk in our supply chain and build on the approach deployed to ensure that we operate as far as possible free from enforced labour, human trafficking and slavery.

• We have successfully implemented Creditsafe Compliance Screening to protect our business by providing in depth knowledge of our existing and future customers, suppliers and partners. This compliance screening generates reports on any instances of adverse publicity, sanctions or prosecutions the business has had, including modern slavery issues, thus enabling a full risk diagnosis of all third parties.

• The Verallia Code of Ethics was communicated to all employees, setting out the ethical principles and commitments of the Verallia Group and the behaviours expected of all employees, irrespective of position, across all levels of the Company.

The Code of Ethics has also been added to the Induction Programme and is issued to all new starters on commencement.

Improvement Plans

As a Company who are committed to preventing slavery and human trafficking in our corporate activities, we will continue to develop our response in understanding and supporting the aims and requirements of the Modern Slavery Act.

To help identify, prevent and mitigate any incidents of modern slavery in our operations and supply chain, we will continue to review our processes and practices to ensure that we identify and manage risks to ensure our ongoing compliance with the Modern Slavery Act.

Some of the key steps we will be focusing on in the financial year to 31st December 2024 will be:-

• Reviewing, updating and progressing our Modern Slavery Action Plan, to help identify and deter hidden labour exploitation. This Action Plan will be based on the multi-stakeholder initiative “Stronger Together”.

• Devising and implementing a programme of Modern Slavery Awareness Training for Supervisors and Managers to make them aware of the risk of modern slavery both within our business, and supply chains.
• Developing a full KPI framework in order to set the pace of and drive, rather than simply track, performance in relation to modern slavery.

Performance Indicators

We currently know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:-

• No incidents of modern slavery are identified during ethical/compliance audits.

• No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

This statement is approved by the Board and is signed on its behalf by Mr Axel Guilloteau, Managing Director.