BOC - Modern Slavery Policy Statement 2018 concerning the year to 31 December 2017

This statement was originally published on 28 June 2019 in accordance with Section 54 of The Modern Slavery Act 2015 by BOC Limited to set out the steps taken in 2017 by BOC Limited to ensure that no form of modern slavery takes place in its operations. This revised statement has been published to include BOC Limited’s indirect holding company, The BOC Group Limited.

About BOC and the Linde Group

The BOC Group Limited is a holding company with approximately 149 employees during 2017 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 from over 100 sites.

BOC Limited’s products 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.

The BOC Group Limited and BOC Limited (together the “BOC Group”) are members of the Linde Group and are wholly-owned subsidiaries of their ultimate parent, Linde AG, in Munich, Germany. The Linde Group is one of the largest global gases and engineering groups with revenues exceeding €17bn and 58,000 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. The Linde Group acts responsibly towards its shareholders, business partners, employees, society and the environment in all its business areas, regions and locations across the globe. The Linde Group is committed to technologies and products that unite the goals of customer value and sustainable development.

BOC Group’s supply chain and the sourcing and selection of suppliers is conducted by reference to the Linde 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 Group has a zero tolerance approach to modern slavery, whether in its own operations or in its supply chain. Linde has carried out risk assessments of its suppliers globally, including those in the UK. 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

The Linde Group supports the UN Global Compact and works to ensure all ten of its principles, which include principles concerning human rights and labour standards, are integrated into our business. This is reflected in a number of policies and position statements which specifically target these topics. These include our Code of Ethics, which sets out how companies and employees within the Linde Group are required to maintain their relationships with customers, suppliers, governments, other businesses, the environment and people and the Linde Group position on Human Rights which commits us to protect and promote human rights and builds upon the Linde Group’s values and principles of safety, integrity, sustainability and respect.

BOC Group also shares these principles with its suppliers through the Linde Group’s Code of conduct for Suppliers which informs BOC Group’s suppliers of its minimum requirements for health and safety, environmental protection, legal compliance and integrity, human rights and labour standards, including our intolerance of any form of forced labour.

Preventing Modern Slavery in our supply chain

Approximately 60% of the of the goods and services purchased by BOC Group are bought in the UK. During 2017 BOC Group continued to ensure that suppliers entering into a BOC Group contract were aware of our Code of Conduct for Suppliers 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 Supplier Code of Conduct 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 Group’s procurement expenditure. Smaller suppliers will also be contractually bound to the code through purchase order terms and conditions.

Preventing Modern Slavery in our own operations

All our employees must comply with, and are protected by, the Linde Group Position Statement on Human Rights and the Code of Ethics. UK Human Resources 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 checks on a monthly basis to ensure that no employee is paid below the minimum wage and conduct 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.

Training in our Code of Ethics is compulsory for all 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. The Supplier Code of Conduct is available to all employees through the Linde Group intranet.

BOC Group 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 our commitment to ethical conduct, please visit our Corporate Responsibility microsite.