Stahl Statement onModern Slavery
The Stahl Group (“Stahl’) strives to conduct its business

2. Stahl’s Policy on Modern Slavery

with the highest standards of integrity and ethical behavior.
This statement sets out the steps taken by us to reduce theModern slavery, or any form of forced or compulsory labour, isrisk of slavery and human trafficking (“Modern Slavery”)

a violation of human rights. We take a strong stance against

taking place within our supply chain and in any part of ourmodern slavery and work to ensure high labour rights standards.

own Business. This statement is made in relation to section

We condemn any form of modern slavery and child labour, and54 of the UK Modern Slavery Act 2015.

shall not participate in the trafficking, recruitment, or receipt
of any persons, by means of threat or abuse of power. We allow

1. Stahl’s Business and Supply Chain overview

employees to resign from their position at any time. By behaving
ethically and honestly with all its partners, we are committed

Stahl Lux 2 SA is the parent company of the Stahl Group withto ensuring that modern slavery does not occur elsewhere andits Headquarters in the Netherlands. As of 29 September 2017,strives only to do business with organizations who uphold

we employ more than 2,100 employees at 13 Manufacturing

similar principles.

Sites and 37 Application Labs in 24 countries. This world
coverage makes us a leading player within the field of process

We commit to the UN Global Compact’s Ten Principles and strive

chemicals for leather and other substrates for the automotive

to conduct its business with the highest standards of integrity(and other transportation), industrial application, interior design,and ethical behavior. This means operating in ways that, at aleisure & lifestyle and apparel & accessories industry amongst

minimum, meet fundamental responsibilities in the areas ofothers. Stahl’s Business is divided in the following areas:

human rights, labor, environment and anti-corruption.

Wet-End Chemicals & Dyes, Leather Finish, Automotive Leather
Chemicals and Performance Coatings & Polymers.

We have a Code of Conduct and Whistleblower rules reflecting
these high standards of integrity and ethical behavior andIn 2016 the Stahl Group reported net sales of € 656 mln.

appointed a Compliance Officer. The Code of Conduct andWhistleblower rules apply to all to its employees. These CodeThe Stahl Group has manufacturing sites in Brazil, China, France,of Conduct and Whistleblower Rules are distributed throughGermany, India, Italy, Mexico, The Netherlands, Singapore,

the local HR departments. Every new employee needs to sign

Spain and the USA. The Stahl Group has organized a central

this Code of Conduct and Whistleblower rules.

procurement team, steered by the group director Procurement.
The regional purchasing managers report to the central team.

We pay close attention to the companies with whom we

The central procurement team sets and monitors the purchasing

cooperate, such as agents, distributors and suppliers and require

strategy, selects suppliers and negotiates the prices for thethese business partners to sign the Business Partner Code ofStahl Group globally. Local sites may take responsibility

Conduct or, if the business partner has its own similar Code offor procurement in case of certain small volumes, which

Conduct, to provide a copy of such Code of Conduct. In case weis monitored by the central team.

find out that the business partner does not comply with the Codeof Conduct, we can, if necessary, immediately discontinue theStahl has furthermore sales (support) offices/representatives
offices, application labs and warehouses to support the saleof its products to customers.

www.stahl.com

business relationship with such business partner.

In the fourth quarter of 2017, we modified the Stahl Code ofConduct for our employees and business partners with more
specific wording on Modern Slavery and these versions will
be signed by employees and business partners.

3. Due diligence Processes for Modern Slavery

The Stahl Code of Conduct is regularly discussed during meetings
with the respective business partners. Such discussions arewritten down in reports and/or e-mails. Furthermore, the Codeof Conduct is regularly mentioned and discussed during theQuarterly Executive Control Group meetings.

Every year, the respective business directors and local
regional managers need to complete a Code of Conduct
compliance questionnaire about the Code of Conduct withrespect to employees and business partners. We refer tothe Stahl Compliance Report as published on the Stahlwebsite (www.stahl.com).

To ensure a high level of understanding of the risks of modern
slavery and human trafficking and to strengthen the awarenessand fortify integer behavior of our employees, we require therelevant Stahl employees to complete e-learning courses aboutmodern slavery, anti-bribery and corruption in the fourth quarterof 2017.

We will continuously work to further develop and strengthen ourefforts to promote the UN Global Compact’s Ten Principles, including
the elimination of all forms of forced and compulsory labor.

This statement has been approved by our Board of Directors.

Huub van Beijeren
Chief Executive Officer

www.stahl.com