Modern Slavery Act

Almet Holding – Group Modern Slavery and Human Trafficking Statement

1) Introduction and scope

This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015. It sets out the steps taken by Almet Holding and the subsidiaries listed in Section 9 to prevent modern slavery and human trafficking in our operations and supply chains during the financial year indicated above.

Almet Trading UK falls within the scope of this Group Statement. Where local laws require additional disclosures or filings, we provide jurisdictional notes or annexes; these supplements should be read together with this Group Statement.

We have zero tolerance for modern slavery, forced labour, child labour, servitude, or human trafficking.

2) Our business and structure

Almet Holding is a fast-growing metals trading and logistics group. We specialize in finished and semi-finished steel products and provide integrated services including sourcing, logistics, document facilitation, trade finance coordination, market intelligence, and quality assurance.

Group footprint: offices in the UK, Turkey, Georgia, and Azerbaijan, with access to strategic ports across the UK and Ireland.
Assurance frameworks: operations are aligned to ISO 9001 quality management practices; for reinforced products we source only from CARES-approved mills (where applicable).

3) Our supply chains

Our supply chains span: steelmaking (upstream raw materials and processing), rolling and finishing mills, freight and port operations (sea, road and rail), storage, customs and documentation services, and professional services.

Key supplier categories:

  • Production mills and processors
  • Ocean, road and rail carriers; port and terminal operators
  • Warehousing and handling providers
  • Finance, inspection and certification partners
  • Professional and technology services

4) Risks of modern slavery in our sector

We recognise elevated risks may occur in:

  • Upstream extraction/processing of raw materials and semi-finished steel in higher-risk geographies
  • Third-party logistics and ports, including use of agency labour and subcontracting
  • Temporary/contract labour in warehousing and handling
  • Indirect suppliers several tiers from our direct contracts

These risks are influenced by country factors, recruitment practices, subcontracting depth, and transparency.

5) Governance, policies and standards

Our approach is built on the following controls:

  • Code of Conduct (employees) and Supplier Code of Conduct (suppliers), prohibiting forced, bonded or child labour; requiring legal wages, safe working conditions, and freedom of movement/association.
  • Contractual clauses: modern-slavery warranties, audit/inspection rights, corrective-action requirements, and termination rights for non-compliance.
  • CARES/ISO 9001 integration: supplier qualification, documented processes, corrective and preventive actions (CAPA), and continuous improvement.
  • Whistleblowing and grievance channels: confidential reporting for employees, suppliers and workers in our supply chains.
  • Board oversight: the Board (or delegated committee) reviews risks, approves this statement annually, and monitors KPI performance.

6) Due diligence and supplier management

We operate a risk-based due-diligence framework applied at onboarding and renewal:

  1. Screening & risk mapping – country/sector risk, ownership checks, sanctions, adverse media, and labour-rights indicators.
  2. Qualification – verification of CARES approval (where relevant), certifications (e.g., ISO 9001), policies on forced labour, and confirmation of right-to-work controls for labour providers.
  3. Contracting – inclusion of modern-slavery clauses, transparency expectations, and audit access.
  4. Monitoring – periodic reviews, documentation checks (e.g., worker age/ID and recruitment fee policies via credible third-party evidence where proportionate), and targeted site visits or third-party audits where risks are higher.
  5. Escalation & remediation – if issues are identified, we require a corrective-action plan with timelines; serious or unremedied breaches may lead to suspension or termination.
  6. Logistics safeguards – expectations for carriers and port operators on ethical recruitment, prohibition of retention of identity documents, appropriate accommodation, and no recruitment fees charged to workers.

7) Training and capability

  • Induction and annual refreshers for relevant teams (sourcing, logistics, quality, legal/finance) on identifying indicators of forced labour and how to escalate concerns.
  • Supplier engagement: sharing of our Supplier Code, guidance on responsible recruitment, and expectations for labour providers.
  • Manager toolkits: checklists for higher-risk geographies and categories; red-flag indicators for audits and site visits.

8) Measuring effectiveness

We track and report progress using key indicators, including:

  • % of new suppliers risk-screened and approved against our standards
  • % of direct spend covered by modern-slavery clauses
  • Number of higher-risk suppliers subject to enhanced review/site visit
  • Training completion rates for relevant employees
  • Issues raised, substantiated cases, corrective actions completed, and time to close
  • CARES/ISO 9001 surveillance outcomes related to supplier and process control

9) Entities covered by this statement

This Group Statement applies to Almet Holding and, at the date of approval, the following subsidiaries and operating units:

  • Almet Trading UK Limited
  • Almet Trading Turkey
  • Almet Trading Georgia
  • Almet Holding
  • ASPM (Almet Steel Production Management)
  • ASMC (Almet Steel Manufacturing Corporation)

(collectively, “the Group”). As the Group evolves, covered entities may be updated in future statements.

UK note: This Group Statement is made on behalf of Almet Trading UK Limited for the purposes of section 54 of the UK Modern Slavery Act 2015.

10) Looking ahead

In the next reporting period we will:

  • Roll out updated Supplier Code of Conduct and require acknowledgment from all new suppliers and targeted existing suppliers.
  • Expand contractor oversight for port/warehouse labour providers with explicit no-fees recruitment commitments.
  • Enhance tier-2 visibility for selected product lines.
  • Strengthen worker-voice options via multilingual reporting channels.

11) Approval

This statement was approved by the Board of Directors of Almet Holding on 3rd October 2025 and signed by:

Last updated: 03/10/2025. This statement will be reviewed and updated annually.