Slavery and Human Trafficking Statement

This statement for the financial year ending 31st March 2024 is made by B.E. Wedge Holdings Limited (“Wedge”) and Wedge Group Galvanizing Limited and published in accordance with Section 54 of the UK Modern Slavery Act (2015), in particular the Transparency in Supply Chains provision, and aims to set out the steps that the company is taking to address and prevent the risk of modern slavery in its operations and supply chains.

Introduction

Modern Slavery is the illegal exploitation of people for personal or commercial gain. Victims are trapped in servitude, which they were deceived or coerced into, and feel they cannot leave. It includes human trafficking. Wedge is committed to preventing slavery and human trafficking occurring in any of its corporate activities, as well as seeking to ensure that our supply chains are also free from such practices.

Our Organisational Structure and Operations

Wedge is the UK based parent company of the group comprising leading galvanizing businesses in the UK, USA and Continental Europe together with a leading UK based designer, manufacturer and supplier of advanced-technology galvanizing equipment to customers around the world. The galvanizing businesses in each region are made up of a network of plants serving mainly domestic customers operating in the construction and related sectors.

Wedge employs over 1,300 people across the UK and USA and has a total annual turnover of circa £280 million*.

Nature of our Supply Chains

The majority of suppliers are domestically and locally based relative to the location of each business e.g. our UK businesses sourcing goods and services from UK based suppliers. There are however a small number of key suppliers from whom we procure raw materials (mainly zinc) and equipment for use in our various processes. These key suppliers have a global presence and are well known to the businesses, having usually supplied them over many years. In respect of zinc which is purchased as a London Metal Exchange (LME) registered brand, since 31st December 2023 all suppliers must meet the LME’s responsible sourcing requirements.

Policy

The company has an Anti-Slavery policy, a copy of which can be provided by sending a written request to the Company Secretary at its registered address. The policy reflects our commitment to implementing and enforcing effective procedures and controls to minimise the risks of human trafficking and other modern slavery practices infiltrating our business operations or supply chains. This policy and others that aim to promote ethical business practices, reiterate elements of the company’s Collective Ambition, a document which describes inter alia our strategic intent and core values.

Risk Assessment

From time to time we assess our own operations and supply chains to identify those elements that potentially represent the highest risks in respect of slavery or human trafficking. The results of the most recent assessment indicated an overall low level of risk on the basis of:-

• Own operations – as these are located in countries where the prevalence of slavery and human trafficking are low, we would expect this to correspond to a low level of risk too. Specifically regarding our own employees, we perceive the risk to be negligible, however there may be a higher risk in respect of temporary employees engaged through agencies.
• Supply chain – our local knowledge developed over time through working with local domestic suppliers would indicate a low level of risk, although a higher level of risk may exist amongst those zinc suppliers with activities in parts of the world where slavery and human trafficking are more commonplace.

Due Diligence Processes

In order to monitor and mitigate the risks of slavery and human trafficking occurring within our supply chains, we aim to undertake the following due diligence processes in relation to suppliers identified as being high risk according to the assessment procedures outlined above:-

• The company utilises centralised purchasing and supplier quality assurance resources for managing supply chain risks in respect of key supplier relationships.
• Suppliers have been engaged with in order to better understand the measures that they have in place to ensure that modern slavery is not occurring within their own operations and supply chains.

Staff Training

We communicate the Anti-Slavery policy to all relevant employees to ensure that they understand the risks of modern slavery and human trafficking infiltrating our business or supply chains and effectively operate our policies and procedures aimed at mitigating this risk.

Monitoring

As a result of our assessment process, we are pleased to confirm that there have been no instances of modern slavery or human trafficking identified in either our own operations or our supply chains during the most recent financial year.

Future Action Update

Further to our assessment, over the course of the next financial year attention will be focused on sustaining communication of the company’s policy regarding modern slavery and human trafficking.

Approved by the Board of Directors on 27^th September 2024.

*The headcount and turnover figures exclude our minority share pertaining to the European galvanizing business