SLAVERY AND HUMAN TRAFFICKING PROCEDURE 2023

From the Steel Solutions NI Ltd Managing Director

I fully endorse the approach in the UK through the Modern Slavery Act 2015 to take responsibility to be alert to the slavery and human trafficking in our business and in the wider supply chain. Staff members are expected to report concerns and management will act upon them

Steel Solutions Organisations Structure

We are a detailer, fabricator and erector of structural steel and cladding. We trade throughout the UK and Ireland. Our head office is in County Fermanagh and fabrication operations across two factory locations.

Our Business

Steel Solutions NI Ltd is a subsidiary of our parent company, Steel Hold Co Ltd

Our Supply Chains

Our supply chains incudes sourcing raw materials for the provision of structural steel buildings

and cladding

Modern slavery and human trafficking policy

We are committed to ensuring that there is no modern slavery or human trafficking in or supply chains or in any part of our business. Our Anti-slavery policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due Diligence of suppliers

As part of the processes of due diligence on slavery and human trafficking we identify and mitigate risk by:

Stating our position to our supply chain and expectation from our partners in business
When building projects in different geographical areas we request our subcontractors and suppliers to commit to comply with the Modern Slavery Act 2015. Failure to do so will terminate our relationship as we have a zero tolerance to slavery and human trafficking.

Effectiveness in combatting slavery and human trafficking

The company use KPls to measure how effective we are at ensuring that slavery and human trafficking does not take place in any part of our business

Audits of our supply chain by our internal auditor and by external auditors are completed

Use of labour monitoring payroll through claims for costs for work on contracts

Level of communication and personal contact with the supply companies and their understanding of compliance to the Modern Slavery Act 2015.

Employee Awareness

Senior staff members have been briefed on the legislation and the company's position on

Modern Slavery Act 2015. The Directors have been briefed on this subject.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our company's slavery and human trafficking statements for the current financial year.

ANTI-BRIBERY AND CORRUPTION POLICY 2023

The Bribery Act 2010 requires that Steel Solutions has a policy that sets out its plans for detailing how to prevent bribery and corruption by the company or its employees. The act also requires that the company monitors its expenditure to ensure compliance to the Act by all employees.

The act requires that we take reasonable measures to operate and carry out our business in an open, traceable and accountable way.

We will do this by:

complying with the legislation
putting in place procedures to prevent the risk of bribery within the company and among any of its customers and suppliers
Training employees on our procedures that address the Bribery act
Addressing bribery and corruption with a zero policy
Monitoring the giving and receiving of gifts and entertainment and ensuring that approval procedures are understood and complied with
To aid compliance and to investigate any repons in accordance with the act
Reviewing the policy at our Management Review Meeting for feedback and effectiveness

Customer /Supplier Relationships

There are occasions when a discount may be offered to secure a competitive price for products purchased or to a key customer to secure a contract. At all times these prices will not benefit either individual and will be serviced through the company accounts. The value of the discount will be deemed a fair and reasonable expectation of the cost.

It is not acceptable to offer, promise or receive financial reward or benefit in kind from a client, supplier, member of staff or any other individual or company to secure a contract, appointment or sale outside of legitimate practices or to gain unfair advantage

Should a member of staff be found or suspected of these practices they will be subject to employment disciplinary procedures. In some circumstances, it may be a subcontractor, supplier or client who maybe struck of Steel Solutions supply chain list.

Whistleblowing Policy

A whistle blower is a person who raises a concern about a wrongdoing in their workplace. In any circumstance where an employee raises a concern in regards to environmental, quality, work practice, employee instruction, health and Safety there will be no reprisals or repercussions by management against the employee. The matter will be addressed to and by the Managing Director for action.

Charities

Charitable contributions made by any individual on behalf of Steel Solutions must benefit a registered charity and not any individual or non-registered charity and must be recorded as a charitable contribution.

Corporate Hospitality

Steel Solutions do entertain their customers, suppliers and subcontractors to establish a channel of communication in terms of partnering in the course of our business. It means that entertainment needs to be appropriate and relevant.

In the same way gifts are still given and received where custom dictates, however they should be at an appropriate level. When giving or receiving gifts or entertainment, it must be done without the intention of the recipient then being subjected to improper influence by a provider.

It should be noted that before any company hospitality is arranged, either in-house or with a third party, the Directors permission is to be confirmed.

Employees should contact the Managing Director with any queries and direction regarding this policy.

CORPORATE SOCIAL AND ETHICAL RESPONSIBILITY 2023

Steel Solutions expects good corporate behaviour and respect to be demonstrated by all its employees in our work processes, our suppliers, customers and each other.

Steel Solutions has a number of policies in place which reflect its commitment to social and ethical responsibility, namely Health, Safety and Environment, Training, Equal Opportunities, Asylum & immigration, as well as staff grievance and disciplinary procedures

Our Quality Management System is fully compliant to BS EN ISO 9001:2015 and we operate a Factory Production Control System certified to BS EN 1090-1:2009+AI:2011 and welding Certificate to BS EN ISO 3834 Part 2. We benchmark our performance continually to try and improve our competitive position.

Employees

Steel Solutions expects a high standard of work from its staff and training is given to improve and develop individuals as required. Best practice procedures are detailed within the standard Operating Procedures available to staff which form the basis of our ISO9001:2015 registration. Our quality Policy and Quality Manual affirm our commitment to continuous improvement of these procedures and practices.

The acceptance of bribes is a disciplinary procedure and could result in instant dismissal from employment. Likewise, fraud and dishonest practices by employees would result in investigation by the Directors and the probability of disciplinary procedures being taken, as detailed within the Steel Solution Staff Manual.

Additionally, our continued success with various external audits provides evidence of our continuous vigilance to creating a socially acceptable and sustainable future through:

Customer Relationships

Steel Solutions recognises that customer satisfaction is important to business success and staff motivation. Contract meetings and discussions are crucial to ensuring that the client and project needs are met to the best possible outcome. Client feedback can be captured during these meetings and action taken to ensure that the highest standards are met.

Where the client does not agree with the service provided by Steel Solutions then the customer complaints will be acted on and detailed in Procedure SLP 2. This will formalise the issue within Steel Solutions procedures and ensure that the matter is resolved satisfactory.

Subcontractors and Suppliers

The supply chain system servicing Steel Solutions will be expected to adhere to the same principles of social and ethical responsibility with regard to working conditions for staff, legal obligations, health and safety procedures and training, adequate insurance and customer satisfaction.

Subcontractors must provide documentation details that meet the requirements Health and Safety and environmental legislation before they commence operations. This also applies to providing insurance details as detailed in OP10 & SLP5 Purchasing procedure. At the Management Review Meetings the subcontractors performance is reviewed from feedback from site supervisors to ensure that their service is up to standard. Local tradesmen are used where possible.

Suppliers are based in UK and Ireland. A base of key suppliers has been established based on ability to supply and provide professional integrity in their service. There is no evidence, or suspicion of employing illegal immigrants, child labour, exploitation of disadvantaged persons, or carrying out other questionable activities. If this situation changed then the Directors would investigate and terminate all trade relations.

Health and Safety

We provide a programme of training in health and safety for our employees to maintain awareness and to promote these areas as key priorities in carrying out duties in our business. Our aim is to comply with the legislation, regulations and codes of practice for our industry. Our health and safety systems have been certified to OHSAS 18001. We audit these systems to continually improve our environment in which we work for the benefit of our employees and visitors to our premises.

Environment

We are certified to BS EN ISO 14001:2015 for our operations. We continually assess the impact our operations are having on the environment and actively look for ways to reduce waste and energy while monitoring our recycling within the company.

Community Engagement

We foster local business relationships through sourcing local labour, equipment and materials whenever possible. We aim to be a good neighbour and each year we provide financial assistance to the local primary school children to enable them to have the opportunity to learn a traditional musical instrument. This has been greatly appreciated by the children, parents and teachers.

We also support young people in local sports clubs. Each year we support the Marie Currie NI, NI Hospice and NI Children's Hospice where we raise money for this charity and encourage the staff to participate.

This demonstrates our commitment to improve the awareness of our company as a member of the local community and economy.

ENVIRONMENTAL POLICY 2023

Steel Solutions (NI) Ltd is committed to minimizing the impact of their activities on the environment through a strategy of:

Complying with the relevant environmental legislation which relate to our environmental aspects through good working practice
Assess all areas of operation with respect to our potential impacts on the environment incorporation of identified control measures necessary to mitigate environmental damage including pollution through our waste streams
review our objectives and targets annually and develop continual improvement programs
Continually improve standards throughout all areas of operation by communicating our procedures to personnel employed by Steel Solutions (NI) Ltd including alignment with and support of our clients polices.
training of personnel on environmental awareness and adopting good environmental principals and practice.

EQUALITY AND DIVERSITY POLICY 2023

General

Steel Solutions aim is to ensure that it provides equal opportunities for all staff and does not discriminate, either directly or indirectly on grounds of sex, sexual orientation, number of hours worked, marital status, race, colour, nationality, ethnic oi- national origins, disability, religion, beliefs or age

No-one will be treated less favourably on these grounds in the company's policies or practices relating to recruitment and selection, training, development or any aspect of employment.

The Equalities Act 2010 sets the rules for ensuring that everyone has a fair chance in their employment and career opportunities.

Scope of policy

The policy applies to the advertisements of jobs, recruitment and appointment to them, training, conditions of work, pay and to every other aspect of employment. It applies to the regular activities and projects organised and run by the company. It applies equally to the treatment of the company's customers, clients and business contacts.

Training and information

Employees who have any queries on this policy or its application should raise these with Cormac McElvaney. Requests for training, in particular for employees who are in supervisory position or who are involved in recruitment should be addressed to Cormac McElvaney.

This policy will be brought to the attention of all employees at Induction.

Investigation and Complaints

Prompt and fair investigation and action will be instituted by the management on any issue relating to discriminatory action or harassment that is brought to their attention. Similarly, investigation will be made into any matter that is identified as potentially discriminatory or which is an opportunity for positive action, which does not infringe legal provisions. The procedure for bringing such matters to the attention of Management is to discuss the problem initially with Cormac McElvaney.

It is important to the company to ensure that employee's feel able to raise such grievances and no individual will be penalised for raising such a grievance unless it is untrue and made in bad faith.

Bullying and Harassment

The company does not allow, support or condone any sexual or racial harassment or any harassment on the grounds of disability or age or of any other personal characteristics and will treat any breach of this policy as a major disciplinary offence, which could result in consideration of dismissal for gross misconduct. Some types of harassment can constitute a criminal offence and can lead to prosecution of individuals.

Definition

Harassment is unwanted conduct of a sexual/racial/ageist nature or conduct based on disability or any other personal characteristics which has the purpose or effect of violating the dignity of women and men apt work or of creating a hostile, intimidating, degrading, humiliating or offensive environment. It can be a form of sex, race, age, disability or other discrimination and in breach of the Act or Regulations. Harassment may be persistent conduct or one isolated incident and may be directed towards and individual or a group.

It can include:

Unwelcome sexual attention
Subjecting someone to insults or ridicule because of their sex, race, age, disability or personal characteristics including actions claiming to be of a humorous nature
Suggesting that sexual favours may result in further advance of a career or that refusal may lead to damage
Lewd, suggestive or over familiar behaviour
Display or distribution of racist, pornographic, sexually suggestive or otherwise demeaning or insulting pictures or written material.

Harassment does not include friendly or social behaviour or language that may occur or be used during the course of work relationships providing that it is acceptable to both parties. It should be remembered that what is acceptable to one person maybe offensive to another.

Procedure

An employee who is subjected to harassment should initially, if possible, ensure that the alleged harasser is made clearly aware that the behaviour complained of is unwelcome and

/or offensive. If this is impractical or unsuccessful the employee should:

Make a formal compliant and discuss the matter confidentially with Cormac McElvaney

Be assured that the company takes such claims seriously and will make every effort to resolve the situation, including any necessary disciplinary action.

Responsibility of Managers

All managers and employees in a supervisory position are responsible for dealing with any harassment or intimidation of which they are aware whether or not a compliant has been made about it. Those acting in this capacity are expected to set an appropriate standard of behaviour.

All employees have a personal responsibility to treat all customers, suppliers, the public and colleagues with understanding and respect.

Victimisation

Any form of victimisation against any employee who either makes a compliant of discrimination or harassment or who assists in investigations relating to alleged discrimination or harassment or who assist in investigations relating to alleged discrimination or harassment will not be tolerated or condoned by the company. Retaliation against such an employee’s will lead to disciplinary action, which could result in consideration of dismissal for gross misconduct.

Monitoring

All employees and job applicants will be asked to complete a form denoting their sex, race, ethnic origin, religion, age and any disabilities. This information will be used only for the purpose of monitoring the effectiveness of the company's equal opportunities policy and meeting statutory obligations.

HEALTH AND SAFETY POLICY 2023

It is the policy of Steel Solutions to ensure so far as is reasonably practicable, the health, safety and welfare of all its employees and others affected by its operations and undertakings.

Steel Solutions (NI) Ltd will:

Establish and implement a Health and Safety Management system as necessary, to manage the risks associated with our activities and premises.
The Management of Steel Solutions will not allow or accept any compromise of Health & Safety for any other objective within any operation or undertaking by Steel Solutions (NI) Ltd.
Regularly monitor our performance and revise our Health and Safety Management system as necessary to ensure we achieve our objective of continuous improvement.
Provide sufficient resources to meet the requirements of current Health and Safety legislation and aim to achieve the standards of “Good Practice" applicable to our activities.
Actively promote an open attitude to Health and Safety issues, physical and mental, and encouraging staff to identify and report hazards so that we can all contribute to creating and maintaining a safe working environment.
Communicate and consult with our staff on all issues affecting their health and safety and in doing so, bring this policy to their attention.
Provide adequate training to all staff to enable them to work safely and effectively and to ensure they are competent in the work they carry out.
Carry out and regularly revise the assessments to identify hazards and existing control measures. We will prioritise, plan and complete any corrective actions required to reduce risks to an acceptable level.
Maintain our premises and all our equipment to a standard that ensures that risks are effectively managed.
Ensure that responsibilities for health and safety are allocated, understood, maintained and fulfilled.
Retain access to competent advice and assistance through in-home and external bodies, ensuring we are aware of relevant changes in legislation and "Good Practice".
Co-operate with other organisations on sites and in these premises to ensure that we are aware of any risks to our staff from their activities.

It is the duty of all of us, when at work to:

Take reasonable care of our own safety.
Take reasonable care of the safety of others who may be affected by what we do or what we fail to do.
Co-operate so that we can all comply with our legal duties.
Ensure we do not interfere with or misuse anything provided in the interests of health and safety.
Report to management any serious or imminent danger.
Report all shortcomings in our protective health and safety arrangements.
Where an employee has an issue with work to be undertaken and they consider being unsafe, the work must stop immediately and be reported to Steel Solutions Management. Where work is stopped for reasons of Health & Safety and is agreed that it must be stopped until a safe system of work is agreed, then this will not have an impact on other rights e.g. employment. Steel Solutions actively promote the interaction of the employee in all such circumstances and will address such issues in finding a resolution to the unsafe issues.

QUALITY POLICY 2023

The directors and management of Steel Solutions (NI) Ltd are committed to operate every aspect of the business to those standards that offer the highest possible quality of product and service to all clients. This is supported a progressive management style that encourages the Quality culture through the Company.

To reinforce this commitment a Quality Management System, designed for BS EN ISO 9001:2015, operates in all areas of the company. The management is committed to the continuous improvement of the Quality Management System by establishing and reviewing quality objectives for all areas of the company. This is to ensure that the company operates effectively and efficiently and meets the needs of customers.

The retention of registration to BS EN ISO 9001:2015 is a minimum requirement for all areas of the company as is the continued search for improvement. The effectiveness of the Quality Management System is monitored by planned audits, management reviews and effective corrective and preventative action.

We implement our weld procedures ta BS EN ISO 3834-2 (Comprehensive Quality Requirements) and our Factory Process Control to BS EN 1090-1 (Execution class 4)

All personnel have been made aware of the management commitment to this policy in particular and quality in general and are encouraged to demonstrate their own support to the system by continuous active participation.