Modern Slavery Act Statement

Introduction

BOLEO remains dedicated to continuing efforts to assess and address modern slavery and child labour risks in its operations and supply chain.

This statement is made on behalf of Boleo Company.

 

Policy, Risk and Audit

The BOLEO Company’s specialist Corporate Social and Environmental Responsibility (“CSER”) team works in partnership with supply chain facing teams to set and monitor adherance to modern slavery and child labour prevention requirements in the supply chain. The BOLEO Company works with its suppliers to help them to understand, adapt their operations, and thus meet our standards through a combination of training, audits and assessments. The BOLEO Company communicates its standards and expectations to suppliers through the BOLEO Ethical and Environmental Code of Conduct (the “Code of Conduct”) which incorporates international labour and human rights principles and national laws. The Code

of Conduct sets out requirements for the BOLEO Company’s own manufacturing operations and its suppliers in relation to labour practices, business ethics, health and safety, responsible sourcing and environmental standards, including prohibiting all forms of slavery, human trafficking, forced labour and child labour.

Risks of modern slavery and child labour are identified at a Company level through a combination of risk assessments, audits and grievance mechanisms and using external reference points such as the US Trafficking in Persons Report.

Within the calendar year of 2023, the identified areas of on-going potential risk within the electronics industry include:

• Forced labour
• Working hours, wages and benefits
• Raw material sourcing

Regular audits are conducted of owned operations and of the supply chain by The BOLEO Company’s specialist CSER team and external independent audit partners. These audits are usually conducted on a semi-announced or unannounced basis. Sedex risk ratings inform the selection of suppliers included in our Sustainable Supply Chain Programme. Audits assess adherence to BOLEO’s Ethical and Environmental Code of Conduct, and associated policies and standards.

 

Training

Maintaining and developing capacity and capability within supplier facing teams is a priority for The BOLEO Company. Where possible, external experts are engaged to enhance the teams’ technical expertise and keep up to date with industry best practice. Training to note during 2023 includes:

• Responsible sourcing experts, TDi Sustainability, conducted an intensive due diligence workshop for internal Sustainability and CSER teams, focusing on adapting to emerging risks and preparing for increasing legislation.
• Training sessions were also conducted with over 50 suppliers throughout the year to ensure they understand the standards required by BOLEO’s Ethical and Environmental Code of Conduct.