MODERN SLAVERY STATEMENT 2017

April 24, 2018 at 2:30 PM

A letter from David Hopkinson, Chief Executive Officer, Multisol Ltd on behalf of the Board of Directors and Executive Committee

INTRODUCTION FROM THE CEO

Multisol Limited operates to the highest standards of safety, quality, professionalism, integrity, health and environmental management, an ethos demanded of every employee.  Multisol Limited and its associated companies (“Multisol”) are committed to improving our practices to prevent all forms of modern slavery (including slavery, servitude, forced or compulsory labour and human trafficking, as well as child labour), taking place in any part of our business, or supply chain.  This statement sets out the steps we have taken during the previous financial year to implement this commitment and we expect the same commitment from our suppliers, contractors and business partners.

Organisation Structure

Multisol is a market leader in the formulation, blending and distribution of high value fuel and lubricant additives, base oils and speciality chemicals. Multisol was established in 1968 and operates across Europe Africa and the Middle East, employing around 190 people at facilities in UK, France, Russia, Mauritius and South Africa. Multisol was acquired by the Brenntag Group in 2011.

Our Supply Chain
We distribute a portfolio of products  from our industry leading suppliers, and support the delivery of these products to our customers, ranging  from global technology leaders and multinational petrochemical companies to regional and local industrial businesses and fuel and lubricant end users. Multisol UK holds accreditations for: ISO 9001, ISO 14001, BS OHSAS 18001, ESAD and is committed to the CBA’s Responsible Care initiative.

Our Policies
For many years, Multisol and parent company, Brenntag UK Holding Limited have been committed to the highest forms of business conduct and ethics in our operations and supply chain. This commitment forms a cornerstone for many of our policies, procedures and our approach to business.

Safety is the top priority at Multisol and responsibility and sustainability are fundamental aspects of the corporate strategy. Multisol recognizes that only through the joint commitment of all stakeholders within the chemical industry can we be sure that any form of slavery is eradicated. Sustainability issues such as health, safety and environmental protection, working practices, supplier management and governance are increasingly important criteria when choosing business partners and making purchasing decisions. Therefore, Brenntag maintains a close and ongoing dialogue with its suppliers and customers.

Our Anti-Slavery, Child Labour and Human Trafficking Policy prohibits the use of child or forced labour in our business and any involvement by Multisol with entities that support prohibited labour practices or human trafficking, including slavery, bonded labour or debt-bondage, or securing labour or services by force, threat, or deception.

Multisol’s supplier/subcontractor requirements mandate that our subcontractors and suppliers adhere to Multisol policies. Multisol expects a joint commitment from its suppliers and subcontractors in support of business conduct and ethics and sustainability and against all forms of slavery and human trafficking. Accordingly, our standard form subcontractor/supplier agreements oblige suppliers and subcontractors to acknowledge and comply with Multisol’s policies in this regard.

Effective Risk Assessment and Management
Multisol has processes in place to support on-going assessment and management of risks associated with our partner engagements, direct business operations and business relationships. We will not work with customers, suppliers or sub-contractors who do not share our commitment to high ethical standards, particularly in relation to modern slavery.

Our Code of Business Conduct & Ethics and whistleblowing policy provide a process for reporting or raising concerns about any wrongdoing to the Group Compliance Officer, in confidence and without fear of retaliation.

Communication

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide group-wide training to staff.  All Directors have received such training and are committed to the subject.  The training criteria are continually assessed to ensure all staff receive regular training.

Progress from FY 2016
Following Multisol’s recognition in 2016 that exposure to the risk of slavery and human trafficking is present in all aspects of our business operations and supply chains, we identified that the greatest risk existed with our subcontractors and suppliers. Given our global platform we were aware that different geographic locations and sectors presented higher risks of slavery and human trafficking than others. Membership of global programs, through our parent company Brenntag UK Holding Limited, has continued to help us to manage this risk.

During the financial year that ended 31 December 2017, Multisol has continued to develop and enhance our risk assessment processes. All suppliers have always been subject to regular audit, however checking the integrity of our supplier’s Modern Slavery Act knowledge and safeguards has been a key focus and area of development. As such improvements have been made to ensure that all Supplier’s supply detailed information to the Multisol Group on their policies, procedures and processes, especially focused on the Supplier’s subcontracting relationships to ensure further transparency.

Furthermore, a programme is in place to monitor this aspect of the audit and ensure (where relevant) additional information/evidence is collated, any concerns Multisol have are escalated internally and addressed with the third party, and that Multisol maintain a right of veto in relation to the use of subcontractors that are not able to provide Multisol Group with enough confidence that the relative protections are in place. Multisol is continually reviewing how we manage the risks associated with Modern Slavery, and we measure our progress to ensure no slavery and human trafficking is present within our operations and supply chain.

We also continue to review our Brenntag policies, processes and training to make sure they appropriately address our commitment to eliminate slavery and human trafficking from our operations.

This statement is made pursuant to section 54(i) of the Modern Slavery Act 2015 and constitutes the Modern Slavery statement for Multisol Limited and its Subsidiaries.

Signed on behalf of the Board of Directors and Executive Committee:

David Hopkinson

Chief Executive Officer

Signed:  April 2018 for financial year 2017 (1 January 2017 to 31 December 2017) for Multisol Ltd.