Opening Statement from the Executive Leadership Team As a responsible corporate citizen, Quaker Houghton and its subsidiaries are committed to preventing acts of modern slavery and trafficking from occurring within its business and supply chain and imposes the same high standard on its suppliers. We seek to ensure that quality and safety standards are maintained though-out our supply chain by well treated and fairly compensated workers in accordance with current laws and regulations. Structure of the Organisation Quaker Houghton (NYSE: KWR) is the global leader in industrial process fluids. With a robust presence around the world, including operations in over 25 countries, our customers include thousands of the world’s most advanced and specialized steel, aluminum, automotive, aerospace, offshore, can, mining, and metalworking companies. Quaker Houghton in the United Kingdom consists of Houghton Limited, Norman Hay Engineering Limited, SIFCO Applied Surface Concepts (UK) Limited, Surface Technology (Aberdeen) Limited, Surface Technology (East Kilbride) Limited, Surface Technology (Leeds) Limited, Ultraseal International Group Limited, Quaker Chemical Ltd and, Quaker Sales Europe BV (UK Branch). In order to produce and supply a broad range of metalworking fluids and industrial coatings and many other products, we work with a range of suppliers, including agency labour and/or professional contract services. Policy Statement Quaker Houghton has a Code of Conduct which explicitly prohibits forced labour and child labour in the most explicit terms. The Code of Conduct applies to all companies and subsidiaries that make up Quaker Houghton, as well as our customers, suppliers and distributors. Policies and Procedures As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains we have adopted the following policies and procedures:
Set the tone from the top through an Executive Leadership Team level communication reinforcing the organisation’s zero tolerance towards modern slavery.
Undertake risk assessments of existing supplier relationships whilst reviewing procurement policies and procedures to ensure that they are capable of responding to any issues identified in the risk assessment.
Ensuring our supplier contracts comply with the code of conduct and the Modern Slavery Act 2015.
Ensure that whistleblowing procedures cover modern slavery reporting.
Implement a targeted training programme to ensure that those responsible for procurement or managing supply chains are aware of the issues.
Risk and Compliance Quaker Houghton believes the risk of slavery and/or human trafficking in our supply chain to be low. Our standard terms and conditions or procurement create a legally binding commitment on our
suppliers to observe and enforce all the relevant requirements of the Modern Slavery Act. We will consider more intense measures, such as auditing or third-part verification for any suppliers that we determine are of medium or high risk in the regard. If we suspect a supplier is involved in such activities we will conduct an inquiry and, if necessary, take correct actions promptly. Given Quaker Houghton’s zero tolerance approach to slavery and human trafficking, we have a dedicated compliance team which consists of representatives from the following departments:
Legal Human resources Supply chain and operations Finance
In addition, a confidential whistleblowing helpline is made available to all of our employees to report any risks, wrongdoing or signs of modern slavery that they may encounter whilst being active in our supply chain. Effectiveness and Key Performance Indicators Quaker Houghton uses relevant management information to measure how successful we have been in ensuring that slavery and human trafficking is not taking place in any part of our business up supply chains. Training We continue to invest in educating our colleagues to ensure that they recognise the risks of modern slavery and human trafficking in our business or supply chains. Through our training programmes, colleagues are encouraged to identify and report any potential breaches of the organisations Code of Conduct. Colleagues are taught the benefits of stringent measures to tackles slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains. Sign Off This statement is made in accordance with section 54(1) of the Modern Slavery Act and constitutes Quaker Houghton’s slavery and human trafficking statement for the financial year ending March 2021. Adrian Steeples SVP, Managing Director EMEA For and on behalf of Quaker Houghton