Stahl Statement onModern Slavery
It is essential for Stahl to conduct business with the highestof excellence around the world, employing around 1,770

level of integrity in all our interactions. In an ever-changing

people (FTE), and around 30% of whom are engaged in productcommercial, regulatory and compliance environment, we strive

development and technical service activities. The operations

to ensure that we conduct business in the most appropriate,

are located in 22 countries, with its registered Head office inethical and transparent way. This statement sets out the steps

The Netherlands. The top ten countries (i.e.: with the highest net

taken by Stahl to mitigate and eradicate the risk of Modernsales) in alphabetical order, are Brazil, China, France, Germany,Slavery and human trafficking in its supply chain. This statement

India, Italy, Mexico, South Korea, Turkey and the USA.

is prepared as per section 54 of the UK Modern Slavery Act 2015.
Stahl’s position and policies on Modern Slavery
What is Modern Slavery?
Modern Slavery means any form of forced labor, prison labor,

Stahl’s Positionindentured labor, bonded labor, debt servitude, state imposed

Modern slavery, or any form of forced or compulsory labour,forced labor and human trafficking, where coercion, threats or

is a violation of human rights. Stahl takes a strong stancedeception are used to intimidate, penalize or deceive workers,

against any form of modern slavery. Stahl condemns modern

thereby creating situations of involuntary work and exploitation.

slavery and child labour, and shall not participate in theModern Slavery is also associated with (the worst) forms of

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

child labor.

of threat or abuse of power. Stahl allows employees to resignfrom their position at any time if they are forced in such a“No one shall be held in slavery
or servitude; slavery and the slave tradeshall be prohibited in all their forms”
United Nations

situation. By behaving ethically and honestly with all its
partners, Stahl is committed to ensuring that modern slavery
does not occur elsewhere and it strives only to do businesswith organizations that uphold similar principles.

Stahl’s Business and Supply Chain overview

Stahl’s policies

Stahl is the world leader in high-performance coatings andStahl is committed to the guiding principles of UN Global

leather chemicals. Stahl specializes in providing products andCompact, the world’s largest corporate sustainability initiative,services to manufacturers of leather, synthetics, textiles andand reports on these principles annually. With this commitment,

other materials used in the automotive, garment, footwear andStahl confirms the alignment of its strategy and operations tohome furnishing consumer industries. As a manufacturer ofthe universal principles of human rights, labor, environmentchemical products, Stahl considers the health and safety of its

and anti-corruption. Stahl’s activities are also aligned with theemployees to be its primary responsibility. Stahl is a role model

17 Sustainable Development Goals (SDG’s) announced at thefor workplace safety, with a low accident frequency rate. ThroughUN General Assembly in 2015, and reports on progress in its

its continuous improvement culture, Stahl also ensures that theannual ESG Report.

impact of its activities on the surrounding ecosystems is limited.

Stahl operates 11 manufacturing sites, 37 technical service
laboratory centers and/or sales support offices and 9 centersstahl.com

UN Global Compact’s Ten Principles

To ensure a high level of understanding of the risks ofStahl is committed to the UN Global Compact’s Ten Principles

modern slavery and to give guidance on behavior, Stahland strives to conduct its business with the highest standards oftrains all employees on its Code of Conduct.

integrity and ethical behavior. This means operating in ways that,at a minimum, meet fundamental responsibilities in the areas ofhuman rights, labor, environment and anti-corruption.

c) Stahl Business Partner Code of Conduct
It is mandatory for business partners (selected with a riskbased approach) to agree and sign the Stahl Business Partner

The Ten Principles are:Code of Conduct or, if the business partner has its own Code Principle 1: Businesses should support and respect theof Conduct, to provide a copy which Stahl validates. In theprotection of internationally proclaimed human rights

unfortunate event that the business partner does not comply

 Principle 2: Make sure that they are not complicit
in human rights abuseswith the Code of Conduct, immediate action is taken, including,if necessary, (immediate) discontinuation of the business Principle 3: Businesses should uphold the freedom

relationship with such business partner. Stahl includedof association and the effective recognition of thespecific wording on Modern Slavery in its Business Partner

right to collective bargaining

Code of Conduct.

 Principle 4: The elimination of all forms of forced
and compulsory labor

Due Diligence Processes

 Principle 5: The effective abolition of child labor

In order to ensure that Modern Slavery is absent from its

 Principle 6: The elimination of discrimination inbusiness activities, Stahl implemented the following due

respect of employment and occupation

diligence procedure.

 Principle 7: Businesses should support a precautionary
approach to environmental challenges
 Principle 8: Undertake initiatives to promote
greater environmental responsibility
 Principle 9: Encourage the development anddiffusion of environmentally friendly technologies
 Principle 10: Businesses should work against corruption
in all its forms, including extortion and bribery

Business Partner Due Diligence procedure
Stahl implemented a Business Partner Due Diligenceprocedure for relevant business partners (selection on arisk-based approach). With this Business Partner Due
Diligence Procedure the compliance-relevant behavior
and the integrity of the (potential) business partner ofStahl is monitored. This procedure will assist our employees
in establishing and maintaining a commercial relationship

Based on these Ten Principles, we implemented ourwith reliable and ethical business partners.

Corporate Responsibility & Sustainability policies, among
which the Stahl Human Rights Policy and the Stahl Code ofStahl Compliance Report (Codes of Conduct)

Conducts for employees and business partners.

Each year, the management team, local managers and sitemanagers complete a Code of Conduct compliance questionnairea) Stahl Human Rights Policy

about the Code of Conduct with respect to employees andIn 2021 Stahl implemented a specific Human rights policy,

business partners. We refer to the Stahl Compliance Reportwhich includes modern slavery.

as published on the Stahl website.

b) Stahl Employee Code of Conduct

Supplier assessment

Stahl’s Employee Code of Conduct and whistleblower rules

In 2019 Stahl began due diligence on the Code of Conductreflect these high standards of integrity and ethical behavior.

by assessing selected suppliers. The scope of this due

The Code of Conduct and the whistleblower rules apply to all

diligence process was amplified significantly in 2020 with theits employees. Every new employee needs to sign this Code ofimplementation of the EcoVadis supplier ratings system,

Conduct and whistleblower rules. Stahl specifically mentions

which is already used throughout much of the chemical industry

Modern Slavery in its Employee Code of Conduct.

supply chain. The EcoVadis assessment is a thoroughstahl.com

CSR assessment that covers Environment, Labour & HumanRights, Ethics and Sustainable Procurement, and will amplify
the understanding of the wider sustainability performance ofour suppliers. The existing Business Partner Code of Conduct
and Business Partner Due Diligence procedures complement
the EcoVadis system. Already in 2020, 66% of Stahl’s total
direct purchasing spend is covered by EcoVadis Supplier
Assessment ratings.

Stahl continuously improves, develop and strengthens its
efforts to promote the UN Global Compact’s Ten Principles,and this includes the elimination of all forms of forced andcompulsory labor.

This statement constitutes the Stahl Statement on ModernSlavery for the financial year ending 31 December 2020.
This statement has been approved by the Board ofDirectors of Stahl Parent B.V.

Huub van Beijeren
Chief Executive Officer

stahl.com