Modern Slavery

Introduction

At Tecomet, we are committed to ensuring that materials used in our products are sourced in an ethical manner. We are committed to ensuring that our supply chain reflects our values and respect for human rights. In line with our corporate culture and ethics, Tecomet is committed to being a good corporate citizen. This includes ensuring the health, safety, and protection of people who come into contact with our products and business, as well as managing our obligations in relation to modern slavery. Under the law, modern slavery includes forced labour, servitude, human trafficking, and other hidden third-party exploitation of workers. We expect a similar commitment from its global supply chain partners.

This statement summarises the approach taken by Tecomet to prevent and address the risk of slavery and human trafficking within the Tecomet Group business and our supply chain. This statement is made in relation to the United Kingdom Modern Slavery Act.

We are fully committed to playing our part in eradicating modern slavery. We advocate transparency and collaboration to eliminate the risks of modern slavery.

Our Organization

Tecomet is a leading metal and materials innovator and contract manufacturer.  We employ almost 2,000 employees, operate globally across 14 campuses and over 19 facilities, and feature unmatched metal converting expertise through forging, casting, machining, additive, and other finishing technologies. We are the largest contract manufacturer to the orthopaedics industry and a top 10 leader for medical device.  We feature leading positions across large joint, spine, extremities and trauma, CMF, minimally invasive, and laparoscopic surgical markets.  Permanent implants, robotic surgery instruments, custom delivery systems and packaging solutions – we fulfil these all to the most exacting tolerances and standards, and with a quality record and reputation that confer security and trust.

Excellence is the watchword throughout all operations, but particularly in customer service, technical expertise and health, safety, and environmental matters.

Supply chain

The Group utilises a global supply chain of suppliers for raw material and other goods and services. All suppliers are required to comply with all applicable laws, rules, regulations, orders, conventions, ordinances, and standards which include all laws related to the prohibition of human trafficking and slave labour. As part of the contracting process with suppliers all contracts include terms and conditions which ensure that suppliers comply with modern slavery legislation. Suppliers are only added to the approved supplier list once such compliance procedures are satisfactorily completed. Approved supplier lists are regularly reviewed and amended, as necessary.

Human Rights

It is the policy of the Group that we will comply with all relevant human rights legislation. We ensure that our compensation for all employees and contractors meets or exceeds legal minimums. Additionally, we strive to ensure we attract the best talent into the organisation, regardless of race, religion or gender. Discrimination of any kind is not tolerated, and action is taken where necessary to address this.

Tecomet Code of Ethics & Business Conduct

Ethics and integrity are foundational to how we conduct ourselves and do business. As an organization, we are all expected to “always do the right thing with trust and commitment”. Supporting Tecomet’ s core values is the Code of Ethics & Business Conduct. Our Code is a reaffirmation of our commitment to conducting our business ethically and to observing applicable laws, rules and regulations. Tecomet’s reputation and continued success is dependent upon the conduct of its employees. Each employee, as a custodian of Tecomet’s good name, has a personal responsibility to ensure that their conduct protects and promotes both the letter of the Code and its spirit of ethical conduct. Their adherence to these ethical principles is fundamental to our future success.

Tecomet Inc. (together with its affiliates, the “Company” or “Tecomet”) established this Code of Ethics and Business Conduct (the “Code”) to aid employees in making ethical and legal decisions when conducting company business and performing their day-to-day duties. Tecomet’s Board of Directors has assigned the Executive Leadership Team (ELT) responsibility for administering, interpreting and enforcing the Code as it relates to Tecomet’s employees. The ELT has delegated day-to-day responsibility for the same to our Employee Compliance Officers. Our Chief Financial Officer and Chief Human Resource Officer have been appointed Compliance Officers for employee compliance under this Code. Tecomet expects its employees to exercise reasonable judgment when conducting company business. Tecomet encourages its employees to refer to this Code frequently to ensure that they are acting within both the letter and the spirit of this Code.

Ethics and Confidential Helpline

Tecomet also operates an Ethics and Confidential Helpline Guidelines, otherwise known as the “Lighthouse” hotline”, which encourages individuals to report wrongdoing in any form, including but not limited to human rights violations, such as modern slavery. The “Lighthouse” hotline”,  allows for anonymous complaints to reduce the risk or fear of retaliation, and can be reached via telephone, text message, web, or email. A copy of the Lighthouse contact details is displayed throughout our sites, with awareness reiterated and discussed as part of our ongoing communication and training.

Commitment

Tecomet is committed to a work environment that is free from human trafficking and slavery, which includes forced labour and unlawful child labour. Tecomet will not tolerate or condone human trafficking or slavery in any part of our global organization. Tecomet employees, subsidiaries, contractors, subcontractors, vendors, suppliers, partners and others through whom Tecomet conducts business must avoid complicity in any practice that constitutes trafficking in persons or slavery.
This commitment applies to all personnel employed by or engaged to provide services to Tecomet, including, but not limited to, employees, officers, and temporary employees of Tecomet and Tecomet’s U.S. and international subsidiaries, and independent contractors.

Internal Hiring Practices

Tecomet undertakes “Right to Work” checks on all direct employees, contractors, associates and suppliers prior to them commencing any role or work with the business. This includes checking, where applicable, that the proposed employee has a valid work permit and is of an appropriate age to work. All new employees joining Tecomet are provided with copies of the relevant guidelines including our Code of Ethics & Business Conduct, which is also explained to them during their onboarding.

Internal Standards and Training (Key Performance Indicators)

Tecomet employees are required to adhere to all applicable laws and standards and to behave in an ethical manner throughout their work for Tecomet as a condition of employment. Tecomet requires its commercial employees who have direct responsibility for supply chain management, as well as personnel responsible for Tecomet’s internal human resources management, to participate in training relating specifically to identifying modern slavery conditions, forced labour and human trafficking issues, and how to mitigate risks within the supply chain. In addition to employee training, Tecomet raises further awareness of modern slavery issues by displaying posters across our UK entity and operating facilities. All employees have an annual awareness training session on the Code of Ethics & Business Conduct and our staff working in our procurement and HR teams complete training on modern slavery awareness and compliance.

Looking Ahead

Tecomet uses a wide range of suppliers who supply goods for sale, provide services to, and otherwise support our operations. The supply chain involved in the manufacture of some of our products is complex, involving multiple levels between Tecomet and the source of raw materials entering the manufacturing process. To effectively manage the risks of modern slavery throughout the entire supply chain, we will continually and actively manage and clearly communicate our expectations down the supply chain to our direct suppliers.

 

For and behalf of the Tecomet Board of Directors

Andreas Weller | President & CEO

Next update QTR 1 2027