Modern Slavery Statement 2023
Last updated March 2023
The Modern Slavery Statement encompasses the combined UK brands;
- Gas Direct Limited
- Gas Direct Cymru Cyfyngedig
- SIG Industrial Gases Limited
Gas Direct Ltd, Gas Direct Cymru Cyf and SIG Industrial Gases Ltd are subsidiaries of Air Products and Chemicals, Inc. (“Air Products”).
This statement is published in accordance with Section 54 of The Modern Slavery Act 2015.
At Air Products, we are opposed to slavery, human trafficking and the use of forced labour of any kind, and we remain steadfast in our commitment to help eradicate modern slavery, both in the UK and around the world. We have established policies and processes in our businesses and supply chains in support of this position. This statement outlines the actions and activities we undertook in our Fiscal Year 2022 (which ended on the 30th of September 2022) to identify modern slavery within our operations and supply chain.
Air Products is a leader in the global industrial gas industry. Our goal is to ensure that Air Products will be the safest, most diverse and most profitable industrial gas company in the world, providing excellent service to our customers.
Our Global Business Overview
- $12.7 billion dollars in sales
- 21,000+ employees worldwide
- >50 countries
- >$70 billion dollars in market cap
- 8 decades in business
- 200,000+ customers
- 1,800 miles of industrial gas pipeline
- 750+ production facilities
- 30+ industries served
The Company has five business segments
- Industrial Gases – Americas
- Industrial Gases – Asia
- Industrial Gases – Europe
- Industrial Gases – Middle East and India
- Corporate and other
The Regional Industrial Gases segments produce and sell atmospheric gases such as oxygen, nitrogen, and argon; process gases such as hydrogen, helium, carbon dioxide, carbon
monoxide and syngas (a mixture of hydrogen and carbon monoxide); and specialty gases. The regional segments distribute gases to customers through a variety of supply modes, including liquid or gaseous bulk supply delivered by tanker or tube trailer and, for smaller customers, packaged gases delivered in cylinders and dewars. For large-volume customers with relatively constant demand, the Company constructs or acquires an on-site plant on or near the customer’s facility or delivers product from one of its pipelines.
The Corporate and other segment includes the Company’s sale of equipment businesses. This segment sells cryogenic and gas processing equipment for air separation, liquefied natural gas process technology and equipment, turbo machinery equipment and services, and distribution equipment, including membrane systems and cryogenic containers. The
Corporate and other segment also reflects costs to provide corporate support functions and global management activities that benefit all segments.
Our Organisation in the UK
Air Products Group Limited is a wholly owned subsidiary of Air Products and Chemicals, Inc., a Delaware corporation, and is our UK group holding company.
Subsidiary companies of Air Products Group Limited include: Air Products PLC, Air Products (BR) Limited, Air Products Llanwern Limited, Air Products Equipment Limited, Cryoservice
Limited, Gas Direct Limited, Dixons of Westerhope Ltd – renamed SIG Industrial Gases Ltd on 1st of October 2022, Gas Direct Cymru Cyf, Air Products Renewable Energy Limited, Beer Gas Cymru Cyf and M&M Gases Limited.
The Board of Directors of Air Products Group Limited has approved this statement on the 2nd of March 2023.
Our UK Supply Chain
In the UK, Air Products sources from 41 countries and 63% of our supplier spend is with UK companies. Our key commodities include: energy, distribution services and equipment, equipment manufacturing, maintenance services and consumable materials.
Our Company is committed to improving visibility into both our domestic and international supply chains. We will continue to undertake projects in 2023 to understand the manufacturing and labour conditions of the materials and services supplied to Air Products.
Policies and Contractual Controls
At Air Products, we have implemented and reviewed policies and contractual controls within our organisation and supply chain to ensure employee and supplier awareness and promote the identification of malpractice.
Any concerns about Air Products can be reported through our whistleblowing line, IntegrityLine. We encourage anyone, including all our business partners, to report, as allowed by local law, misconduct or ethics violations including modern slavery and forced labour. A link to our IntegrityLine is provided on our Purchase Orders. Our IntegrityLine is available in 24 languages. For concerned employees, we offer our IntegrityLine and have a designated officer. We encourage our employees to report any concerns through the whistleblowing line and will support any employee who raises concerns, without fear of retaliation. No incidents of modern slavery were reported through the IntegrityLine during FY22.
Our Company is committed to maintaining and enforcing a Human Rights policy which provides, among other things, that Air Products supports, encourages and values a diverse, multi-cultural workforce and is strictly opposed to the use of child labour or forced labour of any kind, including but not limited to slavery, indentured servitude, human trafficking and all other forms of forced labour. Our Company’s Human Rights policy requires employees at all levels within the organisation to abide by the policy.
During our vendor onboarding process, Vendors agree to abide by Air Products’ Code of Conduct in their dealings with Air Products and we share a link to the document which is available in 24 languages. Our Code of Conduct sets out the ethical actions and behaviours expected of our employees and board members, but also of our agents, consultants, contractors, distributors, joint venture partners, and other third parties with whom we have business relationships.
Our General Terms and Conditions of Purchase require our suppliers to abide by all laws, rules and regulations in effect in the countries and jurisdictions in which they do business, including but not limited to all laws, rules and regulations relating to modern slavery and human trafficking. In FY22, we incorporated in our Terms and Conditions a clause specific to Human Rights, requesting suppliers to abide by Air Products’ Human Rights Policy and all applicable national laws and international treaties concerning human rights, labour rights, and human trafficking and slavery; suppliers are also requested to endeavour to prevent, mitigate, and account for the impacts of their activities in connection with the transactions they have with Air Products on the human rights of individuals directly or indirectly affected by their supply chains. Air Products members of the Procurement Department, in consultation with the Law Department, are trained to ensure that such clauses are included in contracts. We may also require our suppliers, vendors and contractors to demonstrate a commitment to Human Rights and an opposition to slavery and human trafficking by providing Air Products with a copy of their own Human Rights or Anti-Slavery/Human Trafficking policies.
Air Products’ Corporate Audit department occasionally conducts audits and verifications of existing contractual agreements within the Supply Chain organization to ensure compliance with contractual terms, including but not limited to contractual terms relating to legal compliance. We generally do not hire third parties to conduct audits or verifications for such purposes, although we reserve the right to do so in appropriate circumstances. Audits are generally conducted upon 30 days advance notice.
In FY22, we improved the accessibility to our UK Modern Slavery Statement by making it available in the web page footer of our UK website.
Risk Assessment
We have completed human rights assessments for our operations and supply chains. We reviewed the potential for human rights issues, including child and forced labour, in the highest risk countries in which we operate and did not identify any significant risks. From a supply chain perspective, we examined human rights risks relative to procurement spend and supplier location using country-specific risk information from third parties. To further improve our process, we investigated and will implement a third-party solution to social and
environmental risk classification for our supply chain, including but not limited to child and forced labour.
Due Diligence
As stated in our Human Rights policy, we are opposed to slavery, trafficking and forced labour of any kind. Our Human Resources activities, including recruitment processes and remuneration practices, are compliant with UK law.
We use a consistent, global process to evaluate potential risks of third-party intermediaries. The risk assessment considers the work being done, where the work will be performed, compensation amount and method, and the potential for interaction with government officials. For third-party intermediaries that represent medium or high risk, due diligence is completed and includes questions about vendors’ policies addressing human rights awareness, education and training.
Our Expectation of Suppliers Statement declares that we expect our suppliers not to practice any form of forced labour or modern slavery and to comply to UK Modern Slavery Act 2015 and other relevant legislation.
Globally, new suppliers are screened against Sanctioned Party Lists to identify any party which would have been sanctioned for illegal acts, including but not limited to using forced labour, prior to entering into an agreement. For entities on our ERP System, automated screening continues to occur based on designated milestones.
Our Global Capital Procurement organisation includes in their supplier assessment questionnaires at vendor qualification stage questions relative to human rights. Our UK Procurement Operations organisation is implementing a new social and sustainability evaluation process based on criteria including but not limited to spend level and criticality of supply, which will include questions on modern slavery and child labour.
Effectiveness
We have a team from Procurement, HR and Supply Chain to uphold our procedures on modern slavery and sustainability.
Training
We have implemented awareness training on Modern Slavery and Human Trafficking aimed at employees whose roles are key in identifying and mitigating slavery and human trafficking risks.
In FY22, we published on our Internal Website an article raising awareness for employees on forced labour and how to report any suspicion. This article was advertised in European and sub-regional Management Newsletters. To further train our teams, we will present to our Procurement Teams a case study on Modern Slavery case[s] in Europe.
Contact Us
Questions regarding Air Products’ commitment to eradicate slavery and human trafficking, both within its own organization as well as within the organizations with whom Air Products
does business, may be addressed to Sandrine De Oliveira for Europe or Julie O’Brien, Air Products’ Sustainability Director.
Signed by Ivo Bols, President Europe and Africa