UK Modern Slavery Statement

In this statement the “DITH Group” refers to Duferco International Trading Holding S.A. (“DITH”) and its subsidiaries.

The UK Modern Slavery Act 2015 (the “Modern Slavery Act”) requires certain businesses to publish a statement setting out the steps being taken to address modern slavery in their businesses and supply chains. Duferco UK Limited, a company with its registered office at Duferco House, Buntsford Park Road, Bromsgrove, Worcestershire, B60 3DX, United Kingdom (“Duferco UK”), DITH by virtue of being the ultimate holding company of Duferco UK and other companies in the DITH Group supplying goods or services into the UK, are required to comply with the Modern Slavery Act. DITH is accordingly publishing the following statement on behalf of itself and the members of the DITH Group to which the Modern Slavery Act applies.

THE DITH GROUP AND ITS COMMITMENT

The DITH Group is a global leader in the trading and distribution of steel and steel-related raw materials, operating in more than 88 countries worldwide and currently trading approximately 14.5 million tonnes of products every year. The DITH Group is committed to acting in compliance with applicable laws in all its business dealings and relationships, wherever it operates and with whomever it conducts business.

In addition to operating in compliance with applicable laws, the DITH Group is also committed to conducting its business in a fair, honest, and ethical manner. Our governance model is described in the Responsible Practice section of our website. This includes a description of the applicable Global Compliance Framework,  including the Business Principles and Policy of Business Conduct governing the operations of the DITH Group as well as the DITH Group’s Human Rights, Environment, and Health and Safety policies.

MODERN SLAVERY IN THE SUPPLY CHAIN

Consistent with the policies and principles referred to above, the DITH Group takes steps to conduct its affairs in a manner which provides for equal opportunities, respects human rights, provides for the highest standards of health and safety and protects the environment. These include efforts by the DITH Group to prevent modern slavery or human trafficking in our business. Such steps include, amongst others: know your counterparty checks; incorporation in our contracts of clauses requiring our counterparties to comply with applicable laws and our policy of business conduct; and education and training for all of our employees on compliance issues.

In addition, the DITH Group has dedicated corporate functions (including risk management, compliance and legal) to which employees can refer to and address any issue relating to the compliance of the DITH Group with applicable laws. The DITH Group’s Director of Risk and Compliance has been designated as our nominated contact for the Modern Slavery Act supported by a CSR & Sustainability Manager.

In 2023, the DITH Group released its Sustainability Report which addresses key issues of paramount importance to the DITH Group and set a number of Group targets, among which those indicated in the DITH Carbon Reduction Path.

The Group defined also a Supplier Code of Conducted and strengthened its attention to the supply chain conducting a Supplier ESG Risk Analysis involving the main trading suppliers.

Further, in 2023, the DITH Group’s sustainability performance confirmed the Bronze Medal Rating by Ecovadis.

This statement is made pursuant to section 54 of the Modern Slavery Act with respect to the DITH Group’s Financial Year 2023 and its revision was approved as part of the compliance summary presented to the Board of Directors of DITH on February 21, 2024.

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