Anti-Slavery and Human Trafficking Statement

Modern Slavery Act Statement 2023

Introduction

Bodycote is the world’s leading provider of thermal processing services. As the partner of choice for many of the world’s most respected manufacturing companies, we provide a vital link in the manufacturing process that makes the products our customers manufacture fit for purpose. Our thermal processing services encompass a variety of heat treatment techniques and specialist technologies that extend the life of components. These include heat treatment, metal joining, hot isostatic pressing and surface technology, among others.

Our global network operates from over 165 locations in 22 countries with over 4,500 employees. The Company is organised into two customer-focused businesses: Aerospace, Defense & Energy (ADE) and Automotive General Industrial (AGI). It is further divided into three geographical regions: North America, Western Europe and Emerging Markets.

The vast majority of our supply chain is concerned with the supply of energy and industrial gases. Bodycote plc and its subsidiaries undertake all reasonable and practicable steps to ensure that our ethical standards are being implemented throughout the businesses of our suppliers and that local legislation and regulations are complied with.

Bodycote believes that how we do business is just as important as what we do. We are committed to upholding strong governance standards, aligning our approach to key sustainability frameworks and standards, and meeting our legal obligations. An important part of this is our commitment to uphold and advance human rights throughout our business, ensuring everyone who works with and for us is treated with respect, fairness and dignity.

This statement relates to the financial year ending 31 December 2023. It is published in accordance with the Modern Slavery Act 2015.

Risk assessment

Bodycote plc has conducted a risk assessment of our suppliers in our divisions using the UK Government’s published guidance entitled “Transparency in Supply Chains”. Based on this risk assessment we believe our exposure to the risks of modern slavery is low within our own business and supply chain. In addition, we screen all suppliers using Denied Party Screening databases before transacting business with the supplier. The screening covers databases throughout the world including government watch lists, sanctions, and restricted parties.

Bodycote’s Supplier Code of Conduct incorporates our Core Values and all of our suppliers are required to comply with this Supplier Code in order to provide products or services to Bodycote. We expect all of our suppliers to guarantee an individual’s free choice of employment, respect employee freedom of association and the right to collective bargaining and to not use child labour. The Code is available at the following address: www.bodycote.com/investors/governance/our-policies/.

Standards and training

Our Code of Conduct sets out our policy on compliance with legislation, child labour, anti-slavery and human trafficking, trade sanctions and conditions of employment, health, safety, and the environment. The Group prohibits forced, compulsory and underage labour and any form of discrimination. Appropriate mechanisms are in place to minimise the potential for any contravention of these rules.

The Group’s Human Rights Policy is aligned with the Ten Principles of the UN Global Compact, incorporating the United Nations Universal Declaration of Human Rights and the International Labour

Organization Fundamental Conventions, in respect of labour and human rights. The policy reaffirms the Group’s commitment to freedom of association, the abolition of forced or compulsory labour; the elimination of child labour; the elimination of discrimination; and a safe and healthy working environment.

These Codes apply to every person within the Bodycote Group. We are all expected to take personal responsibility for ensuring that our behavior is consistent with these Codes and if not, it may result in disciplinary action. The Codes are available on our website at the following address: www.bodycote.com/investors/governance/our-policies/.

Colleagues working in senior management, human resources and purchasing roles are required to complete dedicated Modern Slavery Act training, and participate in refresher training, at least every three years. This training course includes recognising what modern slavery is and the scale of the problem, the signs to look out for, and how to take appropriate action to manage the risks. The training includes a self-affirmation that the employee will comply with the regulations, associated guidelines and procedures as well as passing an assessment to demonstrate their knowledge of the material. Since 2021 over 99% of those colleagues required to undertake the training have completed it. We plan to deliver refresher training during 2024.

Whistleblowing mechanism

It is essential that everyone working with and for Bodycote is able to raise any concerns, without fear of reprisal, and to have the option to do so anonymously. To facilitate this, we have a robust whistleblowing facility, known as the Open-Door Line, which is available for all employees and temporary workers to report any ethical concerns they may have on a confidential basis in their own language. This includes any circumstances that may give rise to the risk of slavery or human trafficking. The Open-Door Line is an independent, confidential reporting facility (available in local languages by telephone or email).

Bodycote plc and its subsidiaries will assess any instances of non-compliance on a case-by-case basis and will then tailor remedial action appropriately. We will only knowingly trade with those who comply with the Supplier Code of Conduct or those who are taking verifiable steps towards compliance. The Board and Executive Committee receive reports about issues raised via the helpline, if there have been any, as a standing agenda item for every meeting. These cover details on the issue raised and the investigation undertaken. All reports made in 2023 were resolved without any remedial action necessary.

During 2023, we did not identify any instance of modern slavery across our supply chain and no such incidents of modern slavery or human rights violations were reported through our auditing or whistleblowing mechanisms.

Next steps

We will continue to develop our approach to mitigating the risk of modern slavery and human trafficking taking place in our business or supply chain. As part of this, we plan to roll out a new, Groupwide training platform to support learning and development, including on business ethics topics; and refresh and reissue the Modern Slavery Act training during 2024 to all colleagues required to complete the course.

This statement has been approved by the Board of Directors, who will review and update it as required on an annual basis.
Jim Fairbairn Group Chief Executive, Bodycote plc 03 June 2024