1. Policy Purpose

Byrne-Mech Ltd prohibits all forms of modern slavery, human trafficking, forced labour, and child labour in its operations and supply chains. This policy aligns with Ireland’s Criminal Law (Human Trafficking) Act 2008, EU Directive 2011/36/EU, and the EU Corporate Sustainability Due Diligence Directive (CSDDD), while supporting ethical business practices across our metal fabrication activities.

2. Scope

Applies to all employees, contractors, suppliers (including raw material partners), subcontractors, and logistics providers across IE/EU/US and all other international operations.

3. Policy Statement

• Zero Tolerance: Byrne Mech Ltd. is fully compliant with Ireland’s Employment Permits Act 2006 and ILO Forced Labour Convention No.29.
• Ethical Recruitment: Byrne Mech Ltd. prohibits fees charged to workers, passport retention, or deceptive contracts.
• Supply Chain Transparency: Map Tier 1-3 suppliers by Q3 2028, with enhanced due diligence for high-risk regions.

4. Due Diligence Framework

• Risk Assessments: Annual modern slavery risk reviews prioritising steel, aluminium and copper suppliers and subcontractors.
• Supplier Contracts: Byrne Mech Ltd. includes clauses requiring adherence to UN Guiding Principles on Business & Human Rights.
• Audits: Unannounced inspections at subcontractors starting 2026, with findings reported to the Board.

5. Worker Protection

• Wages: Verify through regular payroll audits that all workers are paid at or above the national minimum wage.
• Grievance Mechanism: Confidential whistleblowing portal managed by HR Director, accessible in 8 languages.

6. Training & Awareness

Raheen, Athenry, Co. Galway, Ireland H65 VK28

Email: info@byrnemech.ie +353 91 844271

• Mandatory annual training for procurement/sales teams on recognising slavery risks (aligned with UK Modern Slavery Act Section 54).

7. Compliance & Reporting

• KPIs: Monitor subcontractor audit pass rates and corrective action closure timelines (<30 days).
• Annual Disclosure: Publish modern slavery statement on www.byrnemech.ie, cross-referenced with sustainability reports.

8. Remediation

• Immediate termination of contracts with non-compliant partners after 90-day remediation period.
• Support victim compensation through partnerships with Focus Ireland and Migrant Rights Centre.

9. Governance

• Sustainability Committee oversees implementation, reporting quarterly to the Board.
• External audits by SRA-approved consultants every 24 months.

10. Policy Review

Revised biennially or following changes to EU Regulation 2023/2775 (CSDDD) or Irish legislation.

Approved:

Colin Byrne
Managing Director
Byrne-Mech Ltd
Galway, Ireland

This policy reinforces our commitments under our supported quality and sustainability frameworks, ensuring ethical operations in all markets in which Byrne Mech Ltd. operates.