BOC Modern Slavery Policy Statement 2023

Concerning the year to 31 December 2022

This statement was published in June 2023 in accordance with Section 54 of The Modern Slavery Act 2015 by Linde UK Holdings Limited to set out the steps taken in 2022 by Linde UK Holdings Limited, BOC Limited and The BOC Group Limited, and on behalf of those affiliate companies listed below (the “Companies”) (together “BOC”), to ensure no form of modern slavery takes place in its operations.

About BOC and Linde

Linde UK Holdings Limited and The BOC Group Limited are holding companies for subsidiaries, including BOC Limited. BOC Limited is the UK’s largest industrial, medical, and special gases provider with around 2,387 employees, contractors and agents serving more than 400,000 customer order points.

BOC Limited supplies compressed, bulk and pipeline industrial gases, chemicals, engineering solutions and associated equipment, healthcare innovations, clean energy, and hydrogen transport technologies. BOC serves a variety of end markets including healthcare, pharmaceuticals, chemicals, oil and gas, food and beverage, electronics, and manufacturing including steel and other metals.

BOC companies are wholly owned subsidiaries of Linde plc (“Linde plc”), the ultimate parent company. Linde plc is the Irish holding company of one of the largest global gases and engineering groups with revenues exceeding USD$33 billion and approximately 65,000 employees operating in more than 80 countries in 2022 (“Linde”). Linde acts responsibly towards its shareholders, business partners, employees, society, and the environment in all its business areas and regions across the globe and is committed to technologies and products that unite the goals of customer value and sustainable development. Linde strives to achieve its goals ethically and with the highest of integrity.

BOC’s supply chain and the sourcing and selection of its suppliers is conducted in accordance with Linde’s Global Procurement Standards. Depending on the nature of the product or service, sourcing may be managed on a local, regional, or global basis.

What is Modern Slavery?

Modern slavery is a term that encompasses issues such as people trafficking, forced labour, domestic servitude, slavery, and other forms of human exploitation.

BOC has a zero-tolerance approach to modern slavery, whether in its own operations or in its supply chain.

Our Policies

Linde abides by the principles of the International Bill of Human Rights, enacted by the United Nations. Linde’s corporate policies and position statements make clear Linde’s commitment to its support of human rights and labour standards, and these are integrated into our business and management processes. Linde’s compliance programme aims to ensure adherence to all applicable laws and regulations wherever we operate and for the highest standards when conducting business. Linde seeks to ensure that the value of sustainability and a culture of compliance is understood by our employees and partners.

Linde’s commitment to human rights is provided in its Human Rights Policy and other policies and statements detailed in this statement.

The Linde Code of Business Integrity, available in 31 languages, sets out how companies and employees within Linde, and those acting on its behalf, are required to maintain transparent and respectful relationships with customers, suppliers, governments, other businesses, our environment and people in accordance with Linde’s values, being safety, integrity, accountability, inclusion and community. The Linde Code of Business Integrity commits BOC and its employees to the protection and promotion of human rights and, as such, does not engage in or condone slavery, servitude, or unfair employment practices.

BOC expects its subcontractors and other stakeholders to know and follow the standards described in the Linde Code of Business Integrity and how it affects their role. BOC also shares these principles with its suppliers through the Linde Supplier Code of Conduct (the “Code”). This Code informs BOC’s suppliers of its minimum requirements for health and safety, environmental protection, legal compliance and integrity, human rights, and labour standards, including its intolerance and prohibition of any form of forced or child labour. BOC also expects compliance with minimum working age requirements prescribed by local and national laws.

Preventing Modern Slavery in BOC’s Supply Chain

Approximately 75% of the goods and services purchased by BOC are bought in the UK. During 2022, BOC continued to ensure that existing and new suppliers entering into a BOC contract were aware of the Code. Suppliers representing approximately 86% of BOC’s procurement expenditure have agreed to comply with the Code through its incorporation into the supplier contract. In addition to the requirements of the Code provided above, the Code requires the supplier to undertake reasonable efforts to encourage its own suppliers and sub-contractors to comply with the principles of the Code. The remainder of BOC’s procurement expenditure is made up of smaller suppliers who are also contractually bound to the Code through BOC’s purchase order terms and conditions.

BOC carefully chooses its suppliers based on merit and, where the supplier is key to BOC’s business, a due diligence and approval process is followed by a dedicated team who authorise suppliers before use. BOC expects its suppliers to comply with legal requirements and to act in a manner that is consistent with Linde’s values and principles outlined in the Code, the Linde Code of Business Integrity and Linde’s Conflict Free Material Supply policy.

BOC initiated its supplier audit programme in 2019, by which a questionnaire concerning Modern Slavery issues (the “Questionnaire”) was provided to BOC’s UK supplier base on with a de minimis threshold of £10,000 p.a. The supplier audit programme is carried out on a bi-annual basis, with it being implemented in 2021 and the next iteration in 2023. Any negative or potentially problematic answers are followed up. During 2021, 891 suppliers were issued with the Questionnaire. Our systems have been adapted to track the issuing of new Questionnaires and receipt of responses. The Questionnaire requests information concerning the supplier’s modern slavery statement and related policies, to understand the steps the supplier takes to ensure there is no slavery or trafficking within their business and supply chains, and actions taken for any flagged incidences.

In November 2020, the Questionnaire was incorporated into a new corporate responsibility onboarding document which all new large BOC suppliers are required to complete before commencing business with BOC. This will further feature as part of the new supplier online software application currently being developed.

BOC works hard to deepen relationships with its suppliers and contractors whilst ensuring that they meet BOC’s standards and business values. Linde places a high priority on evaluating risks associated with its supply chain and collaborates with suppliers and stakeholders where involvement makes an impact. On a regular basis we will work with suppliers to improve standards on this area through sharing best practices.

Linde’s Supplier Code of Conduct was updated in March 2023 to further align with Linde’s Human Rights Policy, for monitoring and prevention of human trafficking.

Preventing Modern Slavery in BOC’s Operations

All BOC employees must comply with, and are protected by, the Code of Business Integrity. UK Human Resources and Employee Relations policies meet all UK legal requirements including minimum wage legislation and respect for employee trade union membership and collective bargaining rights. BOC also undertakes appropriate periodic checks to ensure that no employee is paid below the minimum wage and conducts due diligence when recruiting BOC employees, carrying out stringent preemployment checks to ensure proof of identity and the right to work in the UK.

Annual training in BOC’s Code of Business Integrity is compulsory for employees and includes information concerning the Linde Integrity Line, a reporting facility run by an independent third party, which is available to all employees and others including sub-contractors. Linde sets an annual 100% targeted employee certification goal for this training.

BOC has a “see something, say something” culture, without fear of retaliation or fear of punishment. The Linde Integrity Line allows confidential and anonymous reporting by employees and others of all legal and policy violations, including forced labour or unfair employment practices. Retaliation against any person raising an issue is not tolerated. During 2021, updated posters, now with QR codes, were sent to all UK and Ireland sites and an intranet campaign continued to promote the Linde Integrity Line. The Linde Integrity Line is available to all employees and others 24/7 through an online Integrity portal and dedicated telephone number, which is also advertised on the BOC intranet, and is now available through the new employee app launched in November 2022. Links are further provided in management and employee email bulletins, circulated throughout the year.

BOC strives for continuous improvement of its ethics and integrity programme, including in relation to issues of modern slavery. This statement will be periodically updated to reflect these efforts.

Ethical Performance Recognition

BOC and Linde have strong reputations for promoting an ethical culture, as demonstrated in the following recent awards:

Linde was included in the FTSE4Good Index Series, created by FTSE Russell, for the seventh consecutive year in July 2022. The FTSE4Good Index Series is a tool for investors seeking companies that demonstrate strong sustainability practices. Inclusion is based on an independent analysis of environmental, social and governance data. The strict criteria applied has been aligned with the UN Sustainable Development Goals. Within the social pillar, there are three relevant aspects: human rights, labour standards and supply chains.

In April 2023, Linde was recognised, for the third consecutive year, as one of the World’s Most Ethical Companies in 2022 by the Ethisphere Institute, a global leader in defining and advancing the standards of ethical business practices. Honourees were selected from 19 countries and 46 industries and Linde was one of only two companies recognised in the chemicals category. The evaluation framework included ethics and compliance, culture, corporate citizenship & responsibility, governance and leadership & reputation.

Want to Know More?

If you want to know more about our commitment to ethical conduct, please visit the Linde Sustainable Development microsite.

Approved by the boards of the following companies on 23 June 2023 and signed by Jim Mercer on behalf of BOC Limited and Ben Patterson on behalf of Linde UK Holdings Limited, The BOC Group Limited, BOC Helex, BOC Holdings, BOC Investment Holdings Limited and BOC Netherlands Holdings Limited.

Linde UK Holdings Limited
The BOC Group Limited
BOC Limited
BOC Helex
BOC Holdings
BOC Investment Holdings Limited
BOC Netherlands Holdings Limited
Storeshield Limited