MODERN SLAVERY STATEMENT
INTRODUCTION
Respect for People is one of the inspiring principles of the Laminazione Sottile Group, also made official within the Company Values. People are at the heart of our growth process and contribute to the development of our company through passion, creativity and their specific talents, working in teams based on mutual respect.
In this context, we are committed to opposing and preventing all forms of slavery, forced or bonded labour, child labour and human trafficking (hereinafter collectively referred to as “modern slavery”), both in our business and in our supply chain. Modern slavery is indeed a serious crime and a violation of fundamental human rights. This “modern slavery” shows itself in different forms involving the exploitation of an individual by others, for personal or commercial gain. This includes a range of activities ranging from recruitment, to hosting, to transporting, to providing labour through threat or coercion.
This document describes the measures adopted by the Laminazione Sottile Group to ensure the prevention of all forms of “modern slavery, forced labour and human trafficking” within its own operations and in its supply chain, as required by the Modern Slavery Act 2015 - Section 54 of the United Kingdom, the California Transparency in Supply Chains Act of 2010 (SB 657) and the Australian Modern Slavery Act 2018 (No. 153-2018).
This Statement applies to Laminazione Sottile S.p.A. and all its subsidiaries, both directly and indirectly controlled (hereinafter also "LS Group" or “The Group”
THE ORGANIZATION
Laminazione Sottile, founded in 1923, is active in the processing of semi-finished aluminium products. It is the parent company of an entrepreneurial reality that has nine subsidiaries, with ten locations in seven countries around the world (Italy, United Kingdom, Germany, Turkey, United States, Canada and South Korea).
The Group is among the European leaders in the production of rolled aluminium and containers for the food industry, with an export share of over 60% of production.
The production structure is organized into three divisions: Rolling (plain aluminium coils), Coating (lacquered aluminium coils), Container (aluminium containers and rolls).
In 2023, the Group employs approximately 1,300 people, with a total female employment percentage of 19.8%. Considering only the white collars, the female employment figure rises to 38%; within the blue collars sector, which represents three quarters of the workforce employed, a process of employing more women in the production departments of Rolling companies has been started, laying the foundations for progressive numerical growth: in the Container Division companies (classifiable as “light industry”), this is already a consolidated reality, with peaks reaching up to 50% of women workers.
No company in the LS Group employs minors.
THE SUPPLY CHAIN
Responsibility towards People, towards Society and towards the Environment: these are the values of the Laminazione Sottile Group. In compliance with these values, the Group intends to contribute to the development of the territory and to the strengthening of a civil conscience for cultural renewal. This also means carefully selecting services and products from local suppliers where possible, as well as relying on international partners.
Overall, in 2023, the LS Group has approximately 1.400 active suppliers.
In selecting the suppliers suitable for collaborating with the Group, the procurement of the raw material (primary or secondary aluminium) is of particular importance: in this sense, the Group carefully evaluates the reliability of the suppliers as well as the origin of the raw materials, for reasons related both to environmental sustainability and to respect for human and workers' rights.
For key supplies, the Group has structured a centralized Purchasing department, with high technical preparation and, in many cases, works with recognized international groups, with which it has established a relationship of continuous collaboration.
As regards the personnel of external companies present in the plants, the Group only employs highly specialized companies with high quality standards, in compliance with national and international regulations.
All suppliers must be aligned with the Group's values, expressed in the Code of Conduct for Suppliers: the latter is inspired by the main regulations, guidelines and rules existing at national and international level in terms of corporate social responsibility, corporate governance, human rights and the environment. The Code of Conduct for Suppliers integrates and recalls what is already provided for in the Group Code of Ethics and outlines the principles and standards to which each supplier/supplier company must comply when conducting business relations with each Company belonging to the Group. All suppliers are required to aspire to the aforementioned standards in their commercial operations and to have policies and processes in place to comply with and meet the requirements and issues set out therein as we believe that the integration of these principles into company strategies increases the value and competitive advantage of all actors in the supply chain.
POLICY
The Laminazione Sottile Group believes that, among the cornerstones of its business, there is corporate ethics, through which it transmits a message of correctness and respect that is valid for the entire Group and that represents a point of reference in the social reality in which it operates. The parent company maintains a guiding and coordinating role towards its subsidiaries, also through the dissemination and sharing of the ethical principles.
In a context of integrating Social Responsibility into its daily operations, the Group believes that collaboration with the supply chain is fundamental for achieving the highest ethical standards and sustainable business development.
The Group is committed to guaranteeing human rights for all workers, both internal and belonging to the supply chain, and has implemented various policies and procedures to ensure compliance.
These corporate regulatory tools include various commitments and rules of conduct that are fundamental for the prevention of modern slavery.
• The Code of Ethics lays down the intrinsic principles, values and rules of conduct for the work of the Laminazione Sottile Group’s Companies. The Code of Ethics is based on the main current national and international laws, guidelines and regulations on corporate social responsibility, corporate governance, human rights and the environment. The document also cites the principles of corporate ethics and the rules of conduct aimed at preventing the commission, in accordance with Italian law, of the offences provided for by Italian Legislative Decree No.231/2001. This Code applies to all Group companies, in any country and at any level of the organisation, and is addressed to all members of the Board of Directors, Executives, Personnel (employees or otherwise) and Third Parties (customers, suppliers) who carry out activities with and on behalf of the Laminazione Sottile Group, whether employed by the Company or not, in all the countries in which it operates.
The Code of Ethics is available in the Ethics and Compliance section of the website of Laminazione Sottile and of the other companies of the Group.
• The Human Rights Policy is inspired by the Universal Declaration of Human Rights, the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work, the UN Guiding Principles on Business and Human Rights, the LS Group Code of Ethics. It outlines the expectations that the Group places on its Employees and its commitment to supporting a peaceful, participatory and professional work environment. The Policy applies to Laminazione Sottile S.p.A. and all its subsidiaries belonging to the LS Group. The Policy includes all behaviours committed both inside and outside the Group Companies by Employees or contracted workers, regardless of their classification or level of seniority. Therefore, the Human Rights Policy applies in the Group's offices as well as off-site.
The Human Rights Policy is available in the Sustainability section of the website of Laminazione Sottile and of the other companies of the Group.
• The Code of Conduct for Suppliers contains the values, principles and rules of conduct that add to the legal, regulatory and procedural provisions characterising commercial relations between the Group and its partners. All suppliers are required to aspire to the aforementioned standards in their commercial operations and to have policies and processes in place to comply with and meet the requirements and issues set out therein as we believe that the integration of these principles into company strategies increases the value and competitive advantage of all actors in the supply chain.
The purpose of the Code of Conduct for Suppliers is to establish and ensure that all suppliers comply with the minimum requirements required by the Group in terms of compliance with the law, business ethics and integrity, human rights, health and safety of workers and environmental protection in all the facilities in which they operate. In particular, this Code aims to promote fair working conditions and responsible management of social issues throughout the supply chain.
The Code of Conduct for Suppliers is available both in the Ethics and Compliance section and the Suppliers page of the website of Laminazione Sottile and of the other companies of the Group.
• Laminazione Sottile has obtained the SA8000 certification, an international standard on corporate social responsibility, which includes specific requirements on the refusal to use child labour and forced or compulsory labour. In order to correctly implement and apply all the requirements of the SA8000 standard, the Social Performance Team (SPT) was established, coordinated by the Group Compliance function, which is composed of management representatives and workers' representatives.
The Social Responsibility Policy is available in the Social Responsibility section of the Laminazione Sottile website and is included in the Integrated Quality, Safety and Environment Policies of the other companies of the Group.
• The Italian companies of the LS Group have adopted a Model of Organization, Management and Control ex D. Lgs 231/2001, aimed at preventing the administrative liability of the Company for criminal offences committed by its managers, employees and representatives. A special part of the adopted Model requires the Company's management to obtain from suppliers a certification on the compliance, by them and any subcontractors, with labour regulations, including those relating to minimum age, conditions and collective labour agreements.
The general part of the adopted Organizational Model is available in the Ethics and Compliance section of the website of Laminazione Sottile and of the other Italian companies of the Group.
• The Group has implemented a Whistleblowing system accessible to all stakeholders through a dedicated channel, managed by a specialized third party, capable of receiving any reports of alleged or confirmed violations of laws and regulations as well as of the values, principles and rules set out in the aforementioned Codes and in any other company policy or procedure (including those for the protection of human rights and the fight against modern slavery).
To ensure that this system remains accessible and reliable for our collaborators and for all stakeholders, a Whistleblowing Policy has been adopted; it regulates the methods of managing reports, describes how confidentiality and anonymity are protected and guarantees the protection of the whistleblower from any type of retaliation.
The Whistleblowing Policy is available in the Ethics and Compliance - Whistleblowing section of the website of Laminazione Sottile and of the other companies of the Group.
RISK ASSESSMENT
The LS Group is committed to identifying business risks and implementing appropriate management tools for them, through a model in line with the standards recognized for the Enterprise Risk Management (ERM). This ERM model is an integral part of the Internal Control System adopted by the Group, in line with the principles and standards set out in the Group's Code of Ethics.
With regard to the social sphere and respect for human rights, the Group monitors the risks associated with the violation of labour standards.
The Group believes that the risk of modern slavery within its organization is non-existent and that it is low in its production supply chain.
In order to ensure high ethical standards and sustainable development along the entire supply chain, the LS Group promotes monitoring and awareness initiatives along its production chain, constantly monitoring the adequacy of the procurement model. In particular, the risk elements linked to the supply chain are assessed, in terms of impact and probability of occurrence, connected to human rights, child labour, forced and compulsory labour, non-discrimination, freedom of association and collective bargaining, workers' health and safety, working hours, remuneration and regularity of working conditions and disciplinary practices applied.
In order to mitigate the probability and impact of the occurrence of risks of human rights violations in its production chain, the LS Group adopts numerous safeguards related to these topics and, more generally, to promote integrity and ethics in business, with a view to integrating social responsibility and proactive collaboration with its supply chain. In particular, the Group, in addition to a specific Supplier Qualification Procedure, starting from 2024 has disseminated and requested the signature of its Code of Conduct for Suppliers. Suppliers are responsible for ensuring their compliance with the Code, as well as disseminating it and requesting compliance with it from their employees, suppliers and external collaborators.
In the event of serious or repeated violations of the Code, the LS Group reserves the right to terminate the commercial relationship with suppliers, as well as in the event of a failure to reach an agreement regarding the corrective actions to be adopted and/or failure to implement them, or for failure to collaborate in carrying out monitoring activities.
Finally, the Group also encourages communication by its commercial partners , through the whistleblowing channels activated for sending reports of presum ed or confirmed violations of the Code of Conduct for Suppliers .
PERFORMANCE INDICATORS (KPI)
The LS Group constantly monitors the effectiveness of the actions and measures adopted for ethical and responsible business conduct, including the measures used to mitigate slavery risks. In particular, the Group has defined internal KPIs to monitor how the company is exposed to the risk of modern slavery, forced labour and human trafficking (whistleblowing reports) and to measure the performance of the prevention actions undertaken (results of audits conducted on suppliers and number of training activities carried out).
To date, no suspected or confirmed cases of modern slavery or any other violation of human rights have been reported.
TRAINING
The LS Group is committed to raising awareness and maintaining clear communication and training within its organization regarding ethical principles and policies for respecting human rights and labour standards and preventing modern slavery.
During 2021, the Guido Moschini Academy was created for personnel training, and in 2022 the physical location was inaugurated, in order to strengthen the educational offer. The Academy, which initially managed the training of Italian staff only, was subsequently extended to international subsidiaries.
In 2024, on the occasion of the publication of the Whistleblowing Policy, a training program on the Whistleblowing system was launched, which was added to the already structured training relating to the Group's Code of Ethics, the corporate social responsibility management system and Model 231 (which involves managers and employees, including personnel with direct responsibility for supply chain management).
Furthermore, initiatives have been taken to implement the Code of Conduct for Suppliers, providing information and training to recipients, as well as support to achieve full compliance with the principles and provisions contained therein, including the prevention of modern slavery throughout the entire supply chain.
COMMITMENT TO THE FUTURE
The Laminazione Sottile Group considers corporate ethics one of its primary values and promotes respect for the principles of legality, honesty, transparency, good faith, impartiality and correctness. This approach represents the rudder that guides corporate and strategic choices, aimed at creating value for people and territories.
It is therefore essential that respect for human rights and business integrity are a component recognized as a priority along the entire supply chain.
The LS Group is committed to proactively working to encourage the fight against modern slavery, to continuously improve its performance in order to prevent and address potential risks of modern slavery within its operations and supply chain.
As part of this process, the Group is committed to regularly reviewing its policies and procedures to help ensure compliance with relevant laws and regulations as well as addressing any human rights abuses within its sphere of influence.
Marco Evangelista (CE), 15/01/2025
Massimo Moschini President of the Board
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