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UK Modern Slavery Act

The INEOS group of companies (“INEOS”) is committed to operating responsibly and to respecting human rights throughout its operations and within its supply chains. We seek to identify, assess, and address risks relating to forced labour, slavery, human trafficking and other forms of exploitation. This statement sets out the steps taken by INEOS during the financial year ended 31 December 2025 to help ensure that slavery and human trafficking are not taking place within our business or in any of our supply chains.

This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015. ¹

1. INEOS' organisational structure, business and supply chains

INEOS is a global manufacturer of petrochemicals, polymers, speciality chemicals and oil products. In addition to its core chemicals businesses, INEOS trades and ships petrochemical feedstock, has upstream operations that extract oil and gas, operates an Automotive business (producing the Grenadier vehicle), and has various sports interests. 

As of the end of 2025, INEOS had operations at 148 sites across 26 countries, including in Europe, the Americas, and Asia. INEOS supplies products that are essential to modern life, including materials used in healthcare, water purification, food production, housing, transport, renewable energy and industrial manufacturing.  

Our supply chains are global and include the supply of raw materials, energy, equipment, logistics services, construction services, engineering support and other goods and services required to meet our operational requirements. As a participant in complex international supply chains, INEOS recognises that risks relating to labour standards and human rights may arise in certain regions, sectors and in connection with certain labour-intensive activities. We therefore seek to work with suppliers and business partners who demonstrate a commitment to ethical business conduct and respect for human rights. 

2. INEOS policies relating to slavery and human trafficking

The INEOS Code of Conduct outlines the ethical principles which guide the business activities of INEOS. As outlined in the Code, INEOS is committed to ensuring that people are valued and human rights respected throughout our operations and value chains. The Code requires INEOS employees to conduct business in a manner consistent with internationally recognised human rights and labour standards.  

INEOS’ Supplier Code of Conduct sets out the standards we expect our suppliers, their subsidiaries and affiliates, subcontractors and business partners to meet. The Supplier Code is based on the principles of the United Nations Global Compact, to which INEOS became a signatory in 2022, and reflects internationally recognised standards relating to responsible business conduct and human rights.

¹ Only selected INEOS Group subsidiaries are subject to the UK Modern Slavery Act 2015. 

In particular, the Supplier Code expects suppliers to promote fair and inclusive workplaces, respect the rights reflected in the International Bill of Human Rights and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, and provide channels through which employees and other stakeholders may raise concerns regarding potentially unlawful workplace practices. 

The Supplier Code of Conduct also addresses topics including: 

  • Non-discrimination, anti-harassment and abuse;
  • Child labour and underage labour;
  •  Forced labour and human trafficking;
  • Working conditions; and  
  • Freedom of association and collective bargaining. 

3. Due diligence processes relating to slavery and human trafficking

INEOS appreciates that risks associated with labour standards and human rights may vary across our businesses and supply chains. Our due diligence activities are designed to identify, assess and address such risks through a proportionate and risk-based approach. 

3.1 INEOS' own operations

INEOS seeks to identify and mitigate human rights risks across its operations through a combination of governance arrangements, employee training and engagement, reporting mechanisms and ongoing management oversight. Our approach reflects the importance we attach to treating all our workers with dignity and respect and maintaining workplaces that support safe, fair and lawful working conditions. 

3.2 INEOS' supply chain

The principal measures applied in relation to our supply chains include the clear communication of expectations regarding labour standards and human rights to suppliers through the Supplier Code of Conduct, supplier risk assessments and ongoing engagement with key suppliers in these areas. 
Suppliers are expected to conduct business in line with the principles set out in the Supplier Code of Conduct and to communicate similar expectations to their own suppliers and subcontractors. Labour practices and human rights form a core part of the standards expected throughout our value chain. 

3.3 INEOS speak up service

Employees and third-party stakeholders (including contractors, partners and suppliers) can raise concerns regarding unsafe, unlawful or unethical behaviour through the INEOS Speak Up system. Speak Up is a free service hosted by an independent external provider. Reports can be made 24 hours a day via the Speak Up website or by calling a toll-free phone number. Those reporting a concern can do so anonymously. Concerns raised through the Speak Up system are reviewed by the INEOS Speak Up team to determine further action, including referral for investigation by a suitable investigation team.  

3.4 Training and awareness

INEOS recognises that training and awareness play an important role in supporting effective human rights due diligence. INEOS businesses are required to provide targeted training on slavery, child labour, and human trafficking to employees identified as being exposed to risks in these areas.  

Across our operations and projects, we seek to inform workers at our sites (including both INEOS employees and contractors) of relevant standards of conduct, available reporting channels (including the INEOS Speak Up system) and, where appropriate, their rights under applicable labour laws. This is supported through worker induction programmes, the display of educational materials on site and active engagement by management teams during meetings with staff and contractors.  

3.5 Major projects and higher-risk activities

INEOS recognises that certain of its major projects may present elevated labour standards and human rights risks due to the nature of the activities undertaken, including construction, contract labour arrangements, recruitment practices involving temporary workers, logistics services and certain international supply chains.

At INEOS’ Project ONE construction project in Antwerp, INEOS has implemented a range of measures designed to address these risks, support workers and promote the early identification and reporting of concerns. These measures include:

  • Promoting awareness of labour standards and human rights risks among contractors, 
    including through pre-approval assessments of contractors' social risk management 
    systems and monthly social compliance meetings with contractors.
  • Informing workers of relevant standards of conduct and available reporting channels and, where appropriate, information relating to their rights under applicable law through 
    mandatory worker induction processes and the INEOS Code of Conduct.
  • Providing channels through which workers may raise concerns regarding unsafe, unlawful or unethical behaviour (including social risk concerns), including through a project specific grievance mechanism and the INEOS Speak Up system  
  • Regular on-site visits from the project social compliance team and direct engagement with workers, including both INEOS employees and contractor personnel.
  • Reviewing work permits, residence permits and visas for workers, where appropriate.
  • Reviewing labour practices within selected international supply chains supporting the 
    project.
  • Applying limits on subcontracting tiers to support the identification of contractors and their workforce, and to promote clear lines of accountability and oversight across the project workforce.

4. Beyond 2025

INEOS remains committed to respecting human rights and maintaining high labour standards throughout our operations and supply chains. We recognise that risks of forced labour, slavery, human trafficking and other forms of exploitation evolve over time and that effective due diligence requires continual improvement, engagement and vigilance. 
We will continue to strengthen our processes, promote responsible business conduct, encourage transparency in our supply chains and support mechanisms that enable workers and stakeholders to raise concerns safely and confidentially. Through these efforts, INEOS seeks to mitigate the risks of forced labour, slavery and human trafficking within our business and supply chains. 

Signed on behalf of the INEOS Group of companies
Andy Currie

Director

INEOS Limited

Date: 08/10/2026