UK Modern Slavery Statement

In this statement the “DITH Group” refers to Duferco International Trading Holding S.A. (“DITH”) and its subsidiaries.

The UK Modern Slavery Act 2015 (the “Modern Slavery Act”) requires certain businesses to publish a statement setting out the steps being taken to address modern slavery in their businesses and supply chains. Duferco UK Limited, a company with its registered office at Duferco House, Buntsford Park Road, Bromsgrove, Worcestershire, B60 3DX, United Kingdom (“Duferco UK”), DITH by virtue of being the ultimate holding company of Duferco UK and other companies in the DITH Group supplying goods or services into the UK, are required to comply with the Modern Slavery Act. DITH is accordingly publishing the following statement on behalf of itself and the members of the DITH Group to which the Modern Slavery Act applies.

THE DITH GROUP AND ITS COMMITMENT

The DITH Group is a global leader in the trading and distribution of steel and steel-related raw materials, operating in more than 120 countries worldwide and currently trading approximately 17 million tonnes of products every year. The DITH Group is committed to act in compliance with applicable laws in all its business dealings and relationships, wherever it operates and with whoever it works.

In addition to operating in compliance with applicable laws, the DITH Group is also committed to conduct its business in a fair, honest and ethical manner. Our governance model is described in the Responsible Practice section of our website. This includes a description of the applicable Global Compliance Framework  including the Business Principles and Policy of Business Conduct governing the operations of the DITH Group.

MODERN SLAVERY IN THE SUPPLY CHAIN

Consistent with the policies and principles referred to above, the DITH Group takes steps to conduct its affairs in a manner which provides for equal opportunities, respects human rights, provides for the highest standards of health and safety and protects the environment. These include efforts by the DITH Group to prevent modern slavery or human trafficking in our business. Such steps include, amongst others: know your counterparty checks; incorporation in our contracts of clauses requiring our counterparties to comply with applicable laws and our policy of business conduct; and education and training for all of our employees on compliance issues.

In addition, the DITH Group has dedicated corporate functions (including risk management, compliance and legal) to which employees can refer to and address any issue relating to the compliance of the DITH Group with applicable laws. DITH Group’s Director of Risk and Compliance has been designated as our nominated contact for the Modern Slavery Act supported by a CSR & Sustainability Manager which has been appointed in the course of 2020. As a consequence of such appointment DITH has conducted a Group Sustainability Outlook relative to the year 2020 and is expected to release a Corporate Social Responsibility Report for the financial year ended on 30 September 2021. Such assessment followed the ISO 26000 guidelines and is based on the Global Reporting Indicators (GRI) applicable to the DITH business.

In addition to the above, in the course of the financial year ended on 30 September 2021, the DITH Group also adopted a new set of policies concerning human rights, the environment and health and safety in the workplace

This statement is made pursuant to section 54 of the Modern Slavery Act with respect to the DITH Group’s Financial Year 2021 and has been approved by the Board of Directors of DITH on July 29, 2022.