Anti-Slavery Policy

Atlantic Steel Processing Ltd
Modern Slavery and Human Trafficking Statement
April 2019


This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 1st January 2018 to 31st December 2018.

The statement sets down Atlantic Steel Processing Ltd’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.

Organisational structure and supply chains

This statement covers the business activities of Atlantic Steel Processing Limited which are as follows:

Established in 2001, we are one of the UK’s leading steel processing businesses. Based in one of the Mersey docks we offer a decoiling and cutting service to customers’ exact requirements providing a flat steel sheet and plate product ready for further processing.

The private shareholders continue to control the business on a day to day basis as part of a management team that brings some 100 years of experience in the steel processing business.

The company operates from one site located at Vittoria Docks, Birkenhead.

As at 31st December 2018 we had 38 employees and the company turnover was £38m.

Our supply chain includes steel mills from all over the World.

We also source products from a number of local suppliers where possible. Whilst a substantial proportion of our suppliers are based in the UK and Ireland, we also have a range of suppliers from around the world, who vary considerably both in terms of size and our annual spend with them. Our new suppliers are subject to a stringent internal approvals process. Many of our suppliers hold international quality standards and accreditations and are regularly audited by the issuing authorities to ensure adherence to these requirements. We also audit a selection of our suppliers to check compliance with our company’s quality standards. Our suppliers all conform to accredited assurance schemes that are relevant to their geographical location and product supplied. These assurance schemes must also comply with all EU legislation. We have issued our Responsible Supplier Principles to our suppliers as a step to ensure compliance with these requirements in all areas of our organisation.

The Company currently operates in the following countries:

  • UK
  • Ireland

We work with a range of steel suppliers including:

  • Worldwide steel manufacturers, steel stockholders & steel consumers.

As a bulk international steel trader we buy long and flat rolled steel products in significant quantities directly from quality assured steel manufacturers and subsequently sell such products in significantly smaller batches to reputable steel stockholders and steel consumers.

The organiation has undertaken an exercise to identify where we feel modern slavery and human trafficking could most likely occur in our business.

We have identified our key risk to be the following: The purchase of long and flat rolled steel products from steel manufacturers operating in countries where protection against breaches of human rights are generally considered to be relatively limited. We have sought to eradicate any such risk using pragmatic and reasonable solutions.

However, we understand that preventing modern slavery and human trafficking will be an ongoing process and our organisation will endeavour to reduce the risk of this being present in our supply chain year on year. Responsibility for the Company’s anti-slavery initiatives is as follows:

Responsibility for the Company’s anti-slavery initiatives is as follows:

  • Policies: The Directors are responsible for creating and reviewing policies. The process by which policies are developed is looking at best practice and adapting to the needs of the Company.
  • Risk assessments: The Directors are responsible for risk assessments in respect of human rights and modern slavery. To minimise the risk we have taken steps to investigate all suppliers. We are also reviewing their procurement process to include a request for suppliers to provide their policies on modern slavery and human trafficking before they are placed on our organisation’s approved supplier list.
  • Due diligence: The Directors are responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.


To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, we have collaborated with external legal advisors who provided the organisation with an overview of the Modern Slavery Act and advice on the next steps. Other colleagues have also received associated training via appropriate in-house collaboration/tutorials.


The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

  • Whistleblowing policy (in employee handbook) - the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.
  • Employee Code of Conduct - The Code of Conduct sets down the actions and behaviour expected of employees when representing the Company.
  • Corporate Social Responsibility (CSR) Policy - The Company’s CSR policy summarises how we manage our environmental impacts and how we work responsibly with suppliers and local communities.

Due Diligence Processes for Slavery and Human Trafficking

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners, evaluating the modern slavery and human trafficking risks of each new supplier and/or invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The Board of Directors endorses this policy statement and is fully committed to its implementation.