This statement was published in May 2024 in accordance with Section 54 of The Modern Slavery Act 2015 by Linde UK Holdings Limited and Linde UK Holdings No. 2 Limited to set out the steps taken in 2023 by these companies, together with 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 their operations.

Linde UK Holdings Limited, The BOC Group Limited and Linde UK Holdings No. 2 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 worldwide with revenues exceeding USD$32 billion and approximately 63,000 employees operating in more than 80 countries in 2023 (“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.

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 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 to 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 follow the standards described in the Linde Code of Business Integrity and understand how it affects their role. BOC also shares these principles with its suppliers through the Linde Supplier Code of Conduct (the “Code”). This Code, available in 21 languages, informs BOC suppliers of Linde’s minimum acceptable requirements for health, safety and environment, sustainability, integrity and legal compliance, human rights and labour standards, citing Linde’s Human Rights Policy and stating its intolerance and prohibition of any form of forced or child labour, including slave labour and human trafficking. BOC also expects compliance with minimum working age requirements prescribed by local and national laws and international conventions. Suppliers are expected to implement the principles of the Supplier Code or equivalent industry standards in their own supply chains, to establish processes to perform due diligence of their supply chains and respond to requests for information to verify compliance with the law, regulations, or Linde policies.

Approximately 75% of the goods and services purchased by BOC are bought in the UK. During 2023, 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 a de minimis threshold of £10,000 p.a. The supplier audit programme is carried out on a bi-annual basis, having been also implemented in 2021, where 891 suppliers were issued with the Questionnaire, and in 2023 when 1260 suppliers were issued with the Questionnaire. Any negative or potentially problematic answers are followed up. Our systems 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 now features as part of a new supplier online software application.

BOC works hard to deepen relationships with its suppliers and contractors whilst ensuring that they meet BOC’s standards and 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 in 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.

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 pre-employment checks.

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. 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 also available through the employee application.

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.

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

In April 2024, Linde was recognised, for the fourth consecutive year, as one of the World’s Most Ethical Companies in 2023 by the Ethisphere Institute, a global leader in defining and advancing the standards of ethical business practices. 136 honourees were recognised from 20 countries across 44 industries and Linde was the only industrial gases company included in the 2024 list. The evaluation framework included environmental and social impact, culture & ethics, governance and third-party management.

Linde was included in the FTSE4Good Index Series, created by FTSE Russell, for the eighth consecutive year in July 2023. 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, companies are assessed on relevant aspects including human rights & community and labour standards.

In November 2023 Linde was recognised by S&P Global as a sustainability leader, achieving the highest score of any industrial gas company in the 2023 S&P Global Corporate Sustainability Assessment (CSA). Companies are assessed on all aspects of corporate ESG performance and policies, in line with the latest standards of international best practice. Overall, Linde scored in the 100th percentile out of more than 500 chemical companies and achieved the second highest score in the chemicals sector. Linde scored in the 100th percentile for both innovation management and emissions, and in the 99th percentile for human rights.

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 7 May 2024 and signed by Armando Botello on behalf of BOC Limited and by a serving director on behalf of the boards of the below companies:

Linde UK Holdings Limited
Linde UK Holdings No. 2 Limited
The BOC Group Limited
BOC Limited
BOC Helex
BOC Holdings
BOC Investment Holdings Limited
BOC investments No. 5
BOC Netherlands Holdings Limited
Linde Finance UK Limited
Food Service Logistics Limited
Linde Cryogenics Limited