A) ORGANISATION

This statement applies to SDC Trailers Ltd. (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 1^st January to 31^st December 2022.

B) ORGANISATIONAL STRUCTURE

SDC is part of the CIMC Group; a global player within the container, trailer and tanker industries, with annual sales of 110,000 vehicles. Supported by CIMC, SDC follows its own mission and values as we continue to build our future and achieve our vision.

Established in 1978, SDC has grown to be the UK and Ireland's largest semi-trailer manufacturer. We now have four manufacturing plants, based in Toomebridge, Magherafelt, Antrim and Mansfield.

SDC supply trailers to a wide range of companies and have built relationships with the industry’s leading logistics operators, supermarket chains and hire companies.

The labour supplied to SDC Trailers Ltd. in pursuance of its operation is carried out predominantly in the UK

C) DEFINITIONS

The Group considers that modern slavery encompasses:

· Human trafficking;

· Forced and child labour;

· Forced work, through mental or physical threat;

· Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;

· Being dehumanised, treated as a commodity or being bought or sold as property;

· Being physically constrained or to have restriction placed on freedom of movement.

D) COMMITMENT

SDC Trailers Ltd. acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. SDC Trailers Ltd. We understands that this requires an ongoing review of both our internal practices in relation to our labour force and, additionally, our supply chains.

SDC Trailers Ltd. does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the SDC Trailers Ltd. in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in UK and Republic of Ireland.

E) SUPPLY CHAINS

In order to fulfil its activities, SDC Trailers Limited main supply chains include those related to trailer components from UK and Europe. We have zero tolerance to Slavery and Human Trafficking. We expect all those in our supply chain to comply with our values.

F) POTENTIAL EXPOSURE

In general, SDC Trailers Ltd. considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

G) STEPS

SDC Trailers Ltd. carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its main suppliers.

SDC Trailers Ltd. has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, SDC Trailers Ltd. has taken the following steps to ensure that modern slavery is not taking place:

· Review of our Recruitment systems to ensure recruitment practices remain legally compliant.

· Use of the Whistleblowing policy in relation to Modern Slavery and Human Trafficking.

· We have Issued a Modern Slavery questionnaire to our main suppliers. Any concerns arising from this will result in sanctions to bring about immediate improvement/termination of the supplier relationship.

· We strictly use reputable recruitment agencies to source labour who are registered with the REC.

· We check that all potential employees have the right to work in the UK.

H) KEY PERFORMANCE INDICATORS

SDC Trailers Ltd. has set out the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the SDC Trailers Ltd. or its supply chains.

We intend to monitor the following KPIs over the next financial year to measure how effective the processes have been:

· The number of suppliers who have completed and returned the SDC Modern Slavery Questionnaire and have supplied a copy of their Modern Slavery Policy.

· Record of any Whilstle Blowing incidents and the actions taken to rectify issues.

· Completion of a review of our Modern Slavery policy to ensure it continues to be fit for purpose.

I) POLICIES

The SDC Trailers Ltd. has the following policies which further define its stance on modern slavery:

· Modern Slavery Policy

· Recruitment Policy and Procedures

· Making a protected Disclosure Policy

· Purchasing Policy

· Employee Handbook Statement

· Bullying Prevention Policy

· Corporate Social Responsibility Policy

J) SLAVERY COMPLIANCE OFFICER

The SDC Trailers Ltd. has a Slavery Compliance Officer, Jane Millar, Human Resources Manager to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the SDC Trailers Ltd. obligations in this regard.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2010 and will be reviewed for each financial year. It has been approved by the Executive Management team who will undertake to ensure its regular update and implementation of its values and objectives.