Stahl Statement onModern Slavery
It is essential for Stahl to conduct business with the highest

Almost a third of its employees are dedicated technical experts

level of integrity. In an ever-changing commercial, regulatory

based at applications laboratories offering best in class,and compliance environment, we conduct business in an

highly customized service to its global client base. Commercial

appropriate, ethical and transparent way. This statement sets

activities are managed via global business units and regionalout the steps taken by Stahl to mitigate and eradicate the risk

sales organizations, with distribution agreements. Stahl’sof Modern Slavery and human trafficking in its supply chain.

registered Headquarters is in the Netherlands.

This statement is prepared as per section 54 of the UK ModernSlavery Act 2015.

Stahl’s position and policies on Modern Slavery

What is Modern Slavery?

Stahl’s Position

Modern Slavery is any form of forced labor, prison labor,

Modern slavery, or any form of forced or compulsory labour, isindentured labor, bonded labor, debt servitude, state imposeda violation of human rights. Stahl condemns modern slavery

forced labor and human trafficking, in which coercion, threats orand child labour, and shall not participate in the trafficking,deception are used to intimidate, penalize or deceive workers,

recruitment, or receipt of any persons, by means of threat or

thereby creating situations of involuntary work and exploitation.

abuse of power. Stahl allows employees to resign from theirposition at any time. By behaving ethically and honestly with allits partners, Stahl strives to ensure that modern slavery does not“No one shall be held in slavery
or servitude; slavery and theslave trade shall be prohibitedin all their forms”
United Nations

occur elsewhere in the supply chain, and only does business withorganizations that uphold similar principles.

Stahl’s policies
Stahl is committed to the guiding principles of UN Global
Compact, the world’s largest corporate sustainability initiative,
and reports on these principles annually. With this commitment,

Stahl’s Business and Supply Chain overview

Stahl confirms the alignment of its strategy and operations toStahl Parent B.V. and subsidiaries (“Stahl”) is a customer-focused

the universal principles of human rights, labor, environment andgroup that commercializes sustainable coatings for a wide range

anti-corruption. Stahl’s activities are also aligned with the 17of substrates. Stahl’s objective is to achieve the highest customer

Sustainable Development Goals (SDG’s) announced at the UN

service level through providing outstanding service and on-time

General Assembly in 2015, and reports on progress in its annual

delivery of innovative and sustainable products while operating

ESG Report.

safely and in harmony with the environment.

Stahl operates 11 manufacturing sites and 37 strategicallylocated technical service laboratory facilities and sales support
offices in 22 countries and employs approximately 1,800 people,
many of whom are engaged in application engineering andresearch and development of new products and processes.

stahl.com

UN Global Compact’s Ten Principles
Stahl is committed to the UN Global Compact’s Ten Principlesc) Stahl Business Partner Code of Conductand strives to conduct its business with the highest standards of

It is mandatory for business partners (selected with a risk-

integrity and ethical behavior. This means operating in ways that,based approach) to agree and sign the Stahl Business Partner

at a minimum, meet fundamental responsibilities in the areas ofCode of Conduct or, if the business partner has its own Codehuman rights, labor, environment and anti-corruption.

of Conduct, to provide a copy which Stahl validates. In theevent that a business partner does not comply with the CodeThe Ten Principles are:of Conduct, immediate action is taken, including, if necessary, Principle 1: Businesses should support and respect the(immediate) discontinuation of the business relationship withprotection of internationally proclaimed human rightsthat business partner. Specific wording on Modern Slavery is

 Principle 2: Make sure that they are not complicit inincluded in Stahl’s Business Partner Code of Conduct.

human rights abuses
 Principle 3: Businesses should uphold the freedom ofd) Stahl Hiring & Onboarding policy

association and the effective ecognition of the rightA specific reference to compliance to modern slavery is

to collective bargaining

included in Stahl’s Hiring & Onboarding policy.

 Principle 4: The elimination of all forms of forced andcompulsory labore) Stahl Whistleblower policy

 Principle 5: The effective abolition of child labor

Stahl has a whistleblower policy under which employees (and Principle 6: The elimination of discrimination in respectthird parties) can report any (suspicion of) non-compliance.

of employment and occupation
 Principle 7: Businesses should support a precautionary
approach to environmental challenges
 Principle 8: Undertake initiatives to promote greater

Due Diligence Processes / Risk assessment
Stahl applies the following due diligence procedures andactivities in order to prevent the occurrence of modern slavery.

environmental responsibility
 Principle 9: Encourage the development and diffusionof environmentally friendly technologies
 Principle 10: Businesses should work against corruption
in all its forms, including extortion and bribery

Business Partner Due Diligence procedure
The Business Partner Due Diligence procedure applies
to selected business partners (a risk-based approach).
The compliance behavior and integrity of the business
partner is monitored via this procedure, and it enables

Based on these Ten Principles, we implemented ourour employees to establish and maintain commercialCorporate Responsibility & Sustainability policies, amongrelationships with reliable and ethical business partners.

which the Stahl Human Rights Policy and the Stahl Codeof Conducts for employees and business partners.

Stahl Compliance Report (Codes of Conduct)
Each year, the senior management team of Stahl completea) Stahl Human Rights Policya Code of Conduct compliance questionnaire on the Code ofIn 2021, Stahl implemented a specific Human rights policy,

Conduct for employees and business partners. The Stahl

which clearly states (among others) that Stahl rejects any

Annual Compliance Report, published on the Stahl website

form of forced or compulsory labor.

under sustainable development, summarizes this activity,and reports on non-compliance occurrences.

b) Stahl Employee Code of Conduct
Stahl’s Employee Code of Conduct and whistleblower rules

Supplier audit protocol

reflect these high standards of integrity and ethical behavior.

Stahl assesses key suppliers, including those in higher risk

The Code of Conduct and the whistleblower rules apply to all

countries, via the EcoVadis-self assessment system, a standard

its employees. Every new employee needs to sign this Code ofin the chemical industry. The selection of Vendors is based on

Conduct and whistleblower rules. Stahl clearly states (amongspend, supply risk and location in risk countries. The EcoVadisothers) that it condemns any form of modern slavery in its

assessment covers Environment, Labour & Human Rights, Ethics

Employee Code of Conduct.

and Sustainable Procurement. Stahl itself received gold status

stahl.com

from EcoVadis in July 2021, and by the end of 2021 around 80%

With regard to the risk of corruption, bribery, modernof Stahl’s total direct purchasing spend (raw materials andslavery in Stahl’s supply chain, the following Keypackaging) and 44% of the total spend on logistics was covered

Performance Indicators are mentioned: Complianceby EcoVadis assessed suppliers. Stahl proactively takes steps

training, Training sessions on company policies, number

with suppliers to help them improve their rating.

of whistleblower cases treated and the assessment
percentage of direct purchases made from suppliers

Other actions

by EcoVadis.

To detect possible modern slavery incidents, Stahl performedinterviews with 32 staff members around the world. The Chief

Final remarks

Operating Officer paid specific attention to this topic during hisTo the best of our knowledge, Stahl did not have anyvisits of the Stahl sites in the Netherlands, Spain, France, Italy,

incidents relating to Modern slavery in 2021. Stahl will

Germany, India, Singapore, Brazil and Mexico. No modern slavery

continuously improve, develop and strengthen its efforts

situations were observed during these visits, nor reported in theto promote the UN Global Compact’s Ten Principles, andinterviews. Stahl also benchmarked itself for salary with respect

this includes the elimination of all forms of forced andto modern slavery, and no signs of modern slavery or exploitation

compulsory labor.

from low salaries were observed.
This statement constitutes the Stahl Statement on Modern
Training on Modern slavery and trafficking

Slavery for the financial year ending 31 December 2021.

In 2021 employees were obliged to do a series of complianceThis statement has been approved by the Board of Directors

e-learning trainings: Anti-Bribery and Anti-Corruption (95.86%of Stahl Parent B.V.

completed), Disciplinary Action Policy (98.46% completed),
Human rights policy (97.08% completed), Nepotism & Conflictof Interest policy (97.97% completed) and Employee Code ofMaarten Heijbroek

Conduct (97.57% completed). The employee completion rate ofChief Executive Officer

these trainings is monitored by HR and the Stahl Group Tax &Legal manager.

Furthermore, in 2021 the Stahl Group Tax & Legal manager gavecompliance presentations / trainings to various Stahl businessgroups, which included Stahl’s policy on modern slavery.

Key performance indicators to measure effectivenessof steps being taken
Stahl performs an annual review of its risk assessment andcontrol policies in accordance with the requirements of theEFPD on environmental, social, human rights and corruption
risks resulting from its activities. This is included in the Universal
Registration Document (ESG Risk Mapping for Extra-FinancialPerformance Declaration (EFPD) of Wendel (the major Frenchshareholder of Stahl), which can be found on the Wendel website(www.wendelgroup.com).

stahl.com