BOC - Modern Slavery Policy Statement 2017

This statement is published in accordance with Section 54 of The Modern Slavery Act. It sets out the steps taken during 2016 by companies within The BOC Group Limited group of companies, including BOC Limited, to ensure that no form of modern slavery takes place in its operations.

About BOC and the Linde Group

BOC is the UK and Ireland’s biggest industrial, medical and special gases provider, serving more than 300,000 customers from over 100 sites. The products we supply include compressed, bulk and pipeline gases, chemicals, engineering solutions and equipment, healthcare innovations and clean energy and transport technologies. The industries which use our products include steelmaking, refining, chemical processing, environmental protection, wastewater treatment, welding and cutting, food processing and distribution, glass production, electronics and healthcare.

Since 2006 BOC has been part of the Linde Group, one of the largest global gases and engineering companies with revenues approaching €17bn and around 60,000 employees working in more than 100 countries. The strategy of The Linde Group is geared towards long-term profitable growth and focuses on the expansion of its international business with forward-looking products and services. Linde acts responsibly towards its shareholders, business partners, employees, society and the environment in every one of its business areas, regions and locations across the globe. The company is committed to technologies and products that unite the goals of customer value and sustainable development.

BOC’s supply chain and the sourcing and selection of suppliers is overseen by the Linde Global Procurement Standards. Depending on the nature of the commodity, sourcing may be local, regional or globally managed.

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. Linde has carried out detailed risk assessments of its operations globally, including those in the UK and Ireland. These assessments have concluded that the chance of modern slavery happening within our business or supply chain is low. However, this is not a reason for complacency.

Our policies

Linde supports the UN Global Compact and works to ensure all 10 of its principles, including those related to human rights and labour standards, are integrated into our business. This is reflected in a number of policies which specifically target these topics. These include our Code of Ethics which commits us to protecting and promoting human rights and our supplier Code of Conduct which obliges our suppliers not to use any form of forced labour and to comply with all employment and labour laws. We also have targeted position statements covering human rights generally and the issue of Conflict Minerals originating in the Democratic Republic of Congo specifically.

In order to ensure our policies are implemented, we are committed to maintain systems, checks and controls to safeguard against harm to individuals or groups. The due diligence we carry out can be summarised as follows:

Preventing Modern Slavery in our supply chain

We require suppliers to ensure they comply with international standards, best practice and modern slavery laws as well as with our own Supplier Code of Conduct (which prohibits forced labour) and, where appropriate, the Linde Group Position Statement on Conflict Minerals. Where higher risk suppliers have been identified, they must undergo periodic audits to monitor and confirm their compliance with all appropriate rules and laws.

Preventing Modern Slavery in our own operations

UK HR and Employee Relations policies meet all UK legal requirements including minimum wage legislation and respect for employee Trade Union and collective bargaining rights. We also undertake appropriate due diligence when recruiting permanent and temporary staff, carrying out stringent pre-employment checks to ensure proof of identity and rights to work in the UK. We also conduct appropriate checks on any agency suppliers to ensure they are reputable and abide by UK employment legislation.

Training in our Code of Ethics and Supplier Code of Conduct is available to all employees in electronic and classroom based format. 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.

BOC is committed to continual improvement in all aspects of its ethics and integrity programme including in relation to issues of Modern Slavery. This statement will be periodically updated to reflect these efforts.

Want to know more?

If you want to know more about BOC and the Linde Group’s commitment to ethical conduct, please visit our Corporate Responsibility microsite. If you have any questions or comments about BOC’s policy on modern slavery, please email