Modern Slavery Act Statement

Introduction

Senior plc (“Senior” or “the Company”) is committed to preventing slavery and human trafficking in its corporate activities and in its supply chain.

This statement sets out the Company’s actions to assess potential modern slavery risks related to its business and the adoption of processes to minimise any risk of slavery or human trafficking in the Company’s business and supply chain. This statement relates to actions and activities during the financial year to 31 December 2023.

Structure of the Senior plc Group and its supply chain

Senior is an international, market-leading, engineering solutions provider with 26 operations in 12 countries (UK, USA, Canada, Mexico, South Africa, France, Germany, Czech Republic, India, Thailand, Malaysia and China). Senior designs and manufactures high-technology components and systems for the principal original equipment producers in the worldwide aerospace & defence, land vehicle and power & energy markets.

Each Group operation is responsible for managing its own supply chain, although there are circumstances where operations collaborate to jointly purchase materials. A significant proportion of Senior’s supply chain is involved in the purchase of various metals or metal products (such as castings, casings, tubes or sheet metal) from US-based and European suppliers, with a sizeable element of these materials being nominated or directed by our customers.

Relevant policies

We are committed to conducting our dealings, whether with customers, suppliers, employees or the communities in which they are based, with the utmost integrity. To achieve this aim, Senior operates the following policies that include its approach to the identification of modern slavery risks and the steps to be taken to prevent slavery and human trafficking in its operations:

  • Code of Conduct

Senior’s Code of Conduct (the Code) is reviewed on a regular basis and provides a clear framework of principles and guidance that sets out standards of ethical behaviour we expect from all employees and the people that work with us. This includes treating everyone fairly and respecting human rights.

All employees are issued with a personal copy of the Code. All new joiners are issued with a copy of the booklet, which is available in all languages applicable to the Group’s employees. A compulsory Global Code of Conduct online training course including a module on Protecting Human Rights, was rolled out across the Group to all employees during the year.

The Company conducts annual Control Self Assessments, encompassing questions related to the Code, across all operating businesses. These are further supported by internal audits.

  • Responsible Sourcing Policy

Senior has a Responsible Sourcing Policy which establishes the minimum standards we expect from our supply chain. The policy is regularly reviewed and updated; our key suppliers are expected to adhere to the Principles of this policy at all times. Senior has developed 10 key environmental, ethical and social responsibility Principles. These Principles are anchored in internationally recognised standards, including the UN Guiding Principles on Business and Human Rights and the Universal Declaration of Human Rights and are as follows:

1. Business Ethics
2. Wages and Benefits
3. Working Hours
4. Non-Discrimination
5. Child labour
6. Freedom of Association
7. Health and Safety
8. Fair procedures and remedies
9. Harsh and inhumane management practices
10. Environmental Management

The Group’s operations have communicated these principles to all key suppliers.

Senior aims to be a good partner, it and will work with its key suppliers to support any necessary improvements, encourage continual improvement, and recognise good performance.

Failure to comply with Senior’s Principles would result in a review of the supply contract.

  • Human Rights Policy

Senior’s Human Rights Policy clearly sets out the standards we expect from our employees, customers and suppliers regarding Human Rights. At Senior, we strive to do business in a responsible way, respecting the human rights of our workers and everyone we come into contact with. We also expect our suppliers to respect and adhere to the policy. The policy clearly states Senior’s commitment to respecting internationally recognised human rights as set out in the International Bill of Human Rights and the core labour standards recognised by the International Labour Organisation.

We want to work with suppliers who share our commitment to human rights and our expectations concerning the responsibility to respect human rights, and we will take appropriate measures where those expectations or obligations are not met. Where a human rights violation is identified, we’ll work with all parties involved to seek access to remedy, compensation and justice for the victim. We’ll also investigate the root cause so that we can take appropriate steps to prevent such a violation reoccurring.

  • Whistle Blowing Policy

Senior’s long-standing Whistle Blowing policy encourages and enables all its employees, customers and other business partners to report any ethical concerns they may have concerning the direct activities of, or the supply chains of, the Group. This includes any circumstances that may give rise to the risk of slavery or human trafficking. The whistle blowing procedure, which includes an independent third-party reporting portal, is designed to allow workers and other stakeholders to raise any concerns they may have, without fear of retaliation. This service is available in all languages appropriate to our global locations. Senior will not tolerate the harassment or victimisation of a person reporting corporate misconduct in good faith. In addition to the legal protection provided to such persons, Senior will treat retaliation against a person reporting corporate misconduct as a violation of the policy and a serious disciplinary offence.

All reports of suspected unethical or illegal corporate conduct are independently investigated and tracked from inception to resolution and, where necessary, actions are taken to rectify any weakness in the systems that have been identified. All reported whistle blowing incidents are reviewed by the Board of Directors.

Board approval

This statement is made in accordance with section 54 (1) of the Modern Slavery Act 2015 and is applicable to all Senior plc group companies including Senior plc, Senior UK Limited and Lymington Precision Engineers Co. Limited. The statement has been approved by the Company’s Board of Directors on 28 February 2024, who will review and update it annually.

Signed on behalf of the Board by

David Squires

Group Chief Executive Officer, Senior plc

Date: 28 February 2024