Sumitomo Chemical Group Statement against Modern Slavery and Human Trafficking
1. About the Statement
This statement is made pursuant to sections 54(1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement for Sumitomo Chemical (“SCC”) group of companies in scope for purposes of the Act (“SCC Group”) for the financial year ending March 2017. The statement is approved by the board of directors of Sumitomo Chemical (UK) plc (“SCUK”), a wholly-owned United Kingdom subsidiary of SCC.
2. Our Business
SCC Group, comprising of 170 subsidiaries, operates businesses worldwide, including the United Kingdom, in five sectors – petrochemical, energy & functional materials, IT-related chemicals, health & crop sciences and pharmaceuticals – and provides products worldwide that support a wide variety of industries and help people’s daily lives.
SCC Group has a number of group companies operating in the United Kingdom performing different functions, including SCUK, Sumika Polymer Compound U.K., Cambridge Display Technology Limited. SCUK is a distributor of household and professional-use insect control products for the Environmental Health Division of SCC. SCUK serves customers in the United Kingdom and other parts of Europe, the Middle East, and Africa, supplying active ingredients, manufacturing use products, and ready-to-use insect control products together with expert national and EU-level registration support for customers using our active substances in their own products.1
3. Our Supply Chain
SCC Group supply chains spans and covers worldwide, wherever it engages in business and considers that an appropriate management of the supply chains is vital for operating its business in a sustainable manner.
4. Our Philosophy and Initiatives against Modern Slavery and Human Trafficking
A. Our Philosophy
With the Sumitomo Spirit as its cornerstone, the SCC Group has steadily forged ahead for more than 100 years. Sumitomo Chemical’s Corporate Philosophy is based on Sumitomo’s Business Principles and is composed of the Business Philosophy, which integrates the company’s business principles, mission and values; the Corporate Slogan and Statement, which outlines the commitment and pride to be shared in common by directors, officers and employees; and the Sumitomo Chemical Charter for Business Conduct, which lays out the code of behavior serving as the basis for the Company’s compliance system.
B. Initiatives to Ensure Compliance by SCC Group and its Supply Chains
To ensure compliance with applicable laws, regulations and ethical standards against modern slavery and human trafficking by SCC Group personnel or it supply chains, SCC Group has been vigorously carrying out the following initiatives.
(a) Code of Conduct
SCC Group has in place in each of the companies a code of conduct, which sets forth a requirement that all relevant personnel must respect the human rights of others, among other applicable laws, regulations or ethical standards that the relevant personnel are required to comply with.
(b) Speak-up System
Appreciating the importance of building an internal system whereby any sign of compliance violation, including any concern of SCC Group’s business having been involved in modern slavery or human trafficking, is detected in its early stage and removed promptly, or appropriate measures are taken swiftly should there actually be any violation. SCC Group has adopted a dual-channel Speak-Up System equipped with an internal Speak-Up hotline and an external Speak-Up hotline, at not just Sumitomo Chemical, but at all Group companies as far as relevant laws of their respective countries permit it. Under the System, an employee can report any violation or suspected violation of compliance to his or her company’s Compliance Committee or other organization of the same nature via either its internal hotline, or an external hotline which is usually an outside lawyer designated by the company. The company’s supply chains or anyone having any involvement in the company’s business activities may also file a report. Annually, SCC Group, all combined, receive approximately 40 cases of speak-up reporting in total.
(c) Compliance Education and Training
All companies of SCC Group are devoting earnest efforts to ensure strict compliance, including applicable laws, regulations or ethical standards on modern slavery and human trafficking, and periodically provide its members education and training utilizing both face to face and e-learning sessions.
(d) Supply Chain Management
It is SCC Group’s policy to procure supplies such as raw materials and packaging materials from suppliers that operate their business in a socially responsible manner, including operating their business free of modern slavery or human trafficking, and has been encouraging the existing suppliers and future candidates to enhance their efforts on CSR activities through various initiatives.
Among these initiatives is specifically setting a procurement standard under which SCC Group will preferentially procure from suppliers who are most active in CSR activities. This policy is set out in the Group Business Standard of Procurement, which provides guidelines for procurement operating activities for SCC Group companies in Japan and overseas. Also, SCC has compiled five categories in the Sumitomo Chemical Supply-Chain CSR Deployment Guidebook. The second category of this Guidebook prescribes “Human Rights and Labor” and expressly prohibits forced labor and child labor. This Guidebook goes on to further address issues such as “Respecting human rights”, “Regulating working hours”, “Paying appropriate wages”. This Guidebook establishes the overarching guidelines encompassing our commitment to combating modern slavery and human trafficking.
Further, SCC has formulated the Sumitomo Chemical Supply-Chain CSR Deployment Check Sheets to enable suppliers to conduct self-evaluations regarding all items. SCC monitors the implementation of CSR measures by all new suppliers and by current suppliers of raw materials, especially those outside Japan, via the CSR Deployment Check Sheets. Every year, SCC monitors around 10 to 20 new suppliers and around 30 to 40 current suppliers in cooperation with group companies. For suppliers who need to follow-up on problems revealed by the monitoring, SCC furnishes feedback, including point-by-point requests for improvement offered with an eye to providing guidance and training. By seeking to raise awareness of and cooperation in ensuring responsible procurement, SCC aims to prosper alongside our suppliers.2
C. Corporate Social Responsibility Initiatives
To resolve serious global issues such as modern slavery and human trafficking, SCC Group believes that it is important to collaborate with international institutions along with promoting its own CSR initiatives against modern slavery and human trafficking. For that reason, since 2005, SCC Group has been participating in the UN Global Compact, an initiative that seeks to advance universal principles (the “Ten Principles”) on human rights, labor, environment and anti-corruption. Also, in light of the contributions made and its firm commitment, SCC Group has later joined the UN Global Compact LEAD, an exclusive group of sustainability leaders from across all regions and sectors that represent the cutting edge of the UN Global Compact, when it was launched in 2011. Through these initiatives, the SCC Group will contribute to the sustainable development of society, and also help achieve the UN Sustainable Development Goals (SDGs) that are to be resolved across the globe by 2030, which includes taking immediate and effective measures to eradicate forced labor and end modern slavery and human trafficking as one of the goals.
5. Looking Ahead
SCC Group believes that the promotion of respect for human rights and ensuring compliance with applicable laws, regulations and ethical standards, including those relevant to modern slavery and human trafficking, is vital for operating its business in a sustainable manner. As such, SCC Group will continue its initiatives as described above, to identify and address any issues associated with modern slavery and human trafficking throughout its global operations and supply chains.
7th September 2017
Dr. Robert Martin
Managing Director, Sumitomo Chemical (UK) plc.
1. For more information on SCC Group and SCUK business overview, please visit the following links:
2. For more information on our Compliance System and our Supply Chain Management, please visit the following links:
As a result of its studies, SCC Group has concluded that neither SCC Group nor SCUK is legally obliged to produce a statement under Section 54(1) of the Act. SCUK is completely independent of SCC in its business and the annual total turnover of SCUK in FY17 did not exceed GBP 36 million. However, SCC Group has established that it should voluntarily produce a statement in the interests of improving transparency as to the prevention of slavery and the occurrence of such issues within supply chains, in light of the spirit of the Act. It should also be noted that this statement does not constitute or create, any agency, representation or other legal status, including a process agency of SCUK in favour of, or in relation to, SCC or SCC Group in the context of litigation in the UK.