The BOC Group Limited is a holding company with approximately 120 employees during 2019 and acts as a holding company for its subsidiaries. BOC Limited is the UK’s largest industrial, medical and special gases provider with around 2800 employees serving more than 300,000 customers.
BOC Limited’s products include compress,ed, bulk and pipeline industrial gases, chemicals, engineering solutions and equipment, healthcare innovations and clean energy and transport technologies. The industries which use its products include steelmaking, refining, chemical processing, environmental protection, wastewater treatment, welding and cutting, food processing and distribution, glass production, electronics and healthcare.
Following the merger of Praxair, Inc., and Linde AG on 31 October 2018, BOC are now wholly owned subsidiaries under the new holding company, Linde plc, Ireland (“Linde plc”). Linde plc is one of the largest global gases and engineering groups with revenues exceeding $28bn and approximately 80,000 employees operating in more than 80 countries in 2019. Linde plc acts responsibly towards its shareholders, business partners, employees, society and the environment in all its business areas, regions and locations across the globe and 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 its suppliers is conducted by reference to the Linde plc's Global Procurement Standards. Depending on the nature of the product or service, 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 plc abides by the principles of the International Bill of Human Rights, enacted by the United Nations and Linde’s policies and position statements support human rights and labour standards and these are integrated into its business This includes the Linde Code of Business Integrity, which sets out how companies and employees within Linde plc are required to maintain their relationships with customers, suppliers, governments, other businesses, the environment and people and Linde plc’s position on human rights which commits BOC to protect and promote human rights and builds upon the values and principles of safety, integrity, sustainability and respect.
BOC also shares these principles with its suppliers through the Linde Code of Conduct for Suppliers which 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 of any form of forced labour.
Preventing Modern Slavery in BOC’s supply chain
Approximately 60% of the goods and services purchased by BOC are bought in the UK. During 2019, BOC continued to ensure that suppliers entering into a BOC contract were aware of the Code of Conduct for Suppliers (the “Code”) and agreed to comply with the Code through its incorporation into the supplier contract. In addition to those requirements of the Code provided above, the Code also requires the supplier to undertake reasonable efforts to encourage its own suppliers and sub-contractors to comply with the principles of the Code. Such contracts represent 75% of BOC’s procurement expenditure. The remaining 25% are smaller suppliers who are also contractually bound to the Code through BOC’s purchase order terms and conditions. During 2019, BOC initiated a supplier audit programme under which it raised a specific Modern Slavery Act questionnaire with approximately one third of its UK supplier base on a rolling three year basis, such suppliers being selected with an annual revenue above a de minimis threshold of £10,000, and then followed up on any negative or potentially problematic answers.
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 checks on a monthly basis 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 to ensure proof of identity and the right to work in the UK.
Training in BOC’s Code of Business Integrity is compulsory for employees and includes information concerning the Linde Integrity Line, which is available to all employees. 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 in good faith is not tolerated. In April 2019, posters were sent to all UK and Ireland sites and an intranet campaign was launched to promote the Linde Integrity Line. The Linde Integrity Line is available to all employees through the Linde Integrity Portal, which is advertised 24/7 on the BOC intranet.
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.
Want to know more?
If you want to know more about our commitment to ethical conduct, please visit the Linde Sustainable Development microsite.
Approved and signed on behalf of the boards of directors of the Companies on 29 June 2020:
The BOC Group Limited
BOC Investment Holdings Limited
BOC Netherlands Holdings Limited
Linde Canada Holdings Limited
Linde Investments No.1 Limited
Linde North America Holdings Limited
Linde UK Holdings Limited