MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT
Overview
This Modern Slavery and Human Trafficking Statement covers the activities of Macsteel Global Limited (company registration number 15319788) ("Macsteel Global”) as informed by the UK's Modern Slavery Act 2015 (“the Act”), for the period 1 January 2022 to 31 December 2022 (FY22).
Macsteel Global is committed to developing appropriate policies, systems and processes to build an effective response over time to the risk of modern slavery and human trafficking.
Our Organisational Structure, Business and Operations
Macsteel Global was incorporated as a company incorporated in the UK on 2 December 2022. Its registered office is 30 Gresham Street, London, United Kingdom, EC2V 7QP.
It is a holding company of three companies and their subsidiaries.
Macsteel Global's operations involve the provision of business services to group entities.
Risk Identification
We recognise that modern slavery may impact our business activities and we will endeavour to take responsibility for reducing the risk that we might contribute to modern slavery and human trafficking through our operations and supply chains (where applicable).
Risk Assessment
We developed a risk assessment methodology which considers a number of indicators of modern slavery and human trafficking risks including sector and industry, the type of products and services, geographical location and specific entity risk. Our initial risk assessment has indicated that our operations and supply chain overall have a very low potential for modern slavery and human trafficking risks.
Macsteel Global provides management related business services to group entities. Macsteel Global does not have a traditional supply chain at all.
Actions Undertaken
As noted above, we undertook an initial risk assessment to identify any key modern slavery and human trafficking risks that exist within Macsteel Global's operations and supply chains. Where necessary, we will conduct further desktop research to understand our key risk areas. We further prioritised those key risk business and supply relationships, based on where we had the greatest leverage to mitigate the potential modern slavery risks that existed in the relationship.
Governance and accountability framework
Macsteel Global expects all suppliers in our supply chain to have no tolerance for modern slavery and human trafficking. The prevention, detection and reporting of modern slavery and human trafficking in any part of Macsteel Global's business or supply chain is the responsibility of all those working for us.
Macsteel Global's board of directors has overall responsibility for approving Macsteel Global's annual modern slavery and human trafficking statement and ensuring that the company complies with Macsteel Global's obligations under the UK's Modern Slavery Act 2015.
Policies and procedures
Macsteel Global has policies and procedures to ensure we have strong frameworks to enable us to assess and address modern slavery and human trafficking risks, namely:
- Modern Slavery and Human Trafficking Policy for our business that establishes and communicates our commitment to addressing modern slavery risks in our business and driving an accountability for ethical business practices across our organisation;
- Grievance/Whistleblower Procedure that supports and encourages employees to raise concerns anonymously via a third party helpline operated by KPMG.
These policies and procedures complement our existing governance framework which also includes:
- Anti-Bribery and Anti-Corruption Policy;
- Code of Ethics.
Assessing the effectiveness of our actions
We are committed to reviewing the effectiveness of our actions by:
- reviewing our modern slavery processes, with senior management to consider whether we are appropriately identifying and evaluating our modern slavery risks, prior to reporting to the Macsteel Global Board;
- conducting a review of our data sources, to ensure we are appropriately identifying and evaluating our modern slavery risks.
We also intend to monitor our performance against a number of key performance indicators. These will include:
- the number of suspected or identified modern slavery incidents.
FY2023 focus
As this is our first statement, we recognise there are further steps we can take to assess and address the risks of modern slavery in our operations and supply chains and we are committed to a continual process of improvement around identifying and eliminating modern slavery risk.
In FY2023 we are committed to further developing our policies and procedures to ensure we are implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or our supply chains. The main focus areas will be around:
- further development of the due diligence processes on existing and new suppliers.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. It constitutes Macsteel Global Limited’s slavery and human trafficking statement for the financial year ending 31 December 2022.
It was approved by the Board of Macsteel Global Limited on 7 July 2023.