Anti-Slavery Policy
ALTA Performance Materials Modern Slavery & Human Trafficking Statement
ALTA Performance Materials has zero tolerance for modern slavery and human trafficking. We are
committed to conducting business ethically, respecting human rights, and acting with integrity in all
our relationships.
Scope and our business
ALTA Performance Materials is a global manufacturer and supplier of high-performance thermoset
resins and gelcoats used in composite materials across a range of sectors, including transportation,
construction, marine, infrastructure, recreation and renewable energy.
This statement applies to ALTA Performance Materials Holdings Company (UK) Limited and its
affiliates. ALTA has 20 sites across the Americas, Europe, Middle East and Asia. We source raw
materials, packaging, logistics and other goods and services from suppliers located across multiple
regions, reflecting the global nature of our manufacturing and customer base.
ALTA Performance Materials recognises that modern slavery and human rights risks may be
influenced by factors such as geography, sector and the nature of goods and services supplied. We
recognise that such risks can arise anywhere and remain vigilant across all our regions and
operations.
Policies and standards
Our approach is informed by internationally recognised principles and supported by our Anti-slavery
and Human Trafficking Policy and related policies, including our Code of Conduct, Supplier Code of
Conduct, Whistleblowing Policy, and Anti-Bribery and Corruption Policy. These set clear
expectations for our employees and for those who work with us.
Respect for human rights and the prevention of modern slavery form part of ALTA Performance
Materials’ wider commitment to responsible business conduct and responsible sourcing.
Due diligence and risk management
- Supplier Code of Conduct and supplier expectations: ALTA Performance Materials
communicates its expectations to suppliers through its Supplier Code of Conduct and associated
supplier governance processes. Suppliers are required either to acknowledge and commit to our
Supplier Code of Conduct or demonstrate that they operate in accordance with equivalent
standards through their own policies and practices. - Diligence of our counterparties: ALTA Performance Materials has systems in place to ensure that
if any existing or potential counterparties are designated under applicable sanctions regulations,
such companies or persons are notified to us. - Development of supplier governance framework: Since becoming ALTA Performance Materials
on 1 April 2025, focus has been on establishing a Supplier Code of Conduct and communicating
its expectations to suppliers. During the reporting period, together with our counterparty diligence
practices represented the principal element of our supplier governance approach in relation to
modern slavery and human rights.
Following the reporting period, ALTA Performance Materials commenced development of a broader
sustainable procurement programme intended to support responsible sourcing, supplier engagement and the continued enhancement of supplier governance processes which will develop as this
programme evolves.
EcoVadis assessment: During the reporting period, ALTA Performance Materials participated in
the EcoVadis sustainability assessment process as part of its broader approach to supplier
governance and responsible business conduct. EcoVadis assessments provide insight into areas
including labour and human rights management systems, ethics controls and responsible
procurement practices.
Following the reporting period, in March 2026, ALTA Performance Materials was awarded an
EcoVadis Silver Medal. While EcoVadis is only one element of our broader governance approach,
the assessment supports our ongoing efforts to strengthen responsible sourcing and supplier
engagement.
Human rights and forced labour expectations: ALTA Performance Materials recognises that risks
relating to forced labour, human trafficking and other human rights concerns can exist anywhere
within our global supply chains. As our supplier due diligence programme develops, we will continue
to review opportunities to enhance our understanding of potential human rights risks within our supply
chain.
Actions if concerns are identified: Where concerns relating to human rights, labour practices or
ethical conduct are identified, ALTA will seek to engage with the relevant supplier to understand the
issue and determine appropriate actions, which may include corrective measures, escalation or,
where necessary, termination of the business relationship.
Reporting and grievance mechanisms
We encourage anyone connected with our business, including workers in our supply chains, to report
concerns. Reports can be made under our “SpeakUp” whistleblowing arrangements. We do not
tolerate retaliation against anyone who raises a concern in good faith.
Training and awareness
ALTA Performance Materials recognises that employee awareness and training are essential for
combating modern slavery and human trafficking. During 2026, we will provide dedicated training on
modern slavery and human trafficking to relevant colleagues to help them identify, prevent and
address modern slavery risks in both our operations and our supply chains. We will report on
progress made in our next annual statement.
Governance and approval
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 for the financial
year ending 31/12/2025 and covers its in-scope subsidiaries.
Approved by the Board and signed on behalf of the ALTA Performance Materials Group of
Companies
Andrew Miller