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Modern Slavery

Stemcor Modern Slavery and Human Trafficking Statement 2023

Stemcor is committed to ensuring that there are no practices of modern slavery or human
trafficking that take place within Stemcor Global Holdings Limited and its subsidiaries. We
continue to review and develop our Group practices to adhere consistently with regulation in
this area. We have set out below our transparency statement under the UK Modern Slavery
Act 2015 and the Australian Modern Slavery Act 2018 for the 2023 financial year.

This statement is published on behalf of Stemcor Global Holdings Limited and each of its
subsidiary commercial organisations carrying on business in the UK with a turnover of more
than £36 million, and our companies undertaking business in Australia or being Australian

About Stemcor

Stemcor is a leading independent service provider for the steel industry. We play a vital role,
acting as an intermediary between customers and suppliers. Stemcor trades steel, we do not
produce it. We make complex transactions easy for buyers and sellers.

With our specialised expertise and knowledge, we help customers choose from over 3,500
different grades of steel and raw materials available in the market. With our global
infrastructure and connections, we ensure they get their product at the right time, and at the
right place. For suppliers, we use our relationships and long-standing expert knowledge to
ensure that their products reach the best customer in the right destinations. We have a history
of working with customers who require specialised steel products including those in the oil and
gas, and automotive industries.

Stemcor’s structure, its business and its supply chains

As a trading company, our key supply chain is our people. We employ approximately 240
people across 26 locations in 5 continents. Therefore, the focus of our efforts in relation to
Modern Slavery is directed towards our workforce. Our workforce is assessed as being at low
risk of modern slavery. On an annual basis we undertake a groupwide review which has again
this year given us high confidence that we do not have any forms of modern slavery taking
place within our organisation; and we have processes in place to ensure it will not happen.

Stemcor’s policies in relation to human trafficking

We require the highest standards of professional and ethical conduct of all our people and are
therefore committed to ensuring that there is no modern slavery or human trafficking in our

Our company Ethics Policy sets out the principles and standards that guide the way we do
business. It explicitly states that ‘we will protect human rights and not be complicit in any
human rights abuses’, including modern slavery and child employment, and equally applies to
all our employees, across all functions and businesses globally.

Stemcor’s due diligence process in relation to slavery and human trafficking in our
business and supply chains

We have systems in place to help manage supply chains external to our business, including
counterparty on-boarding processes. We comply with all relevant laws and regulations, both
internationally and in the geographies in which we operate.

The training about slavery and human trafficking available to Stemcor’s staff

All Stemcor employees are required to read and comply with the company policies, including
modern slavery. Additionally, all our business unit heads are given refresher modern slavery
training annually by email to ensure awareness of modern slavery remains current.

Key Performance Indicator Targets

For the start of 2023 year, we set two KPI Targets in relation to modern slavery being that (1)
all business units will return their annual modern slavery returns by the required deadlines and
(2) we seek to find zero instances of modern slavery through that annual review process. Both
KPI’s were met for 2023. These KPI’s have been reset for the 2024 year.

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015
and section 16 of the Australia Modern Slavery Act 2018 and constitutes our slavery
and human trafficking statement for the financial year ended 31 December 2023.

Steve Graf
Group CEO
January 2024


STEMCOR is a leading, independently run, service provider for the steel industry. We play a vital role by acting as an intermediary between suppliers and customers.


Stemcor Group Longbow House 4th Floor, 14-20 Chiswell Street London EC1Y 4TW United Kingdom
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