imc (the respective legal entity in question) is also referred to as ‘imc’ or ‘Scheer IMC’.
Last Update: 10 February 2026
Scheer IMC is committed to upholding the highest standards of ethical conduct and human
rights throughout our operations and supply chain. We recognise the seriousness of modern
slavery and human trafficking and are dedicated to preventing these abuses in all aspects of our
business. This policy outlines our commitment to compliance with the UK Modern Slavery Act
and all other pertinent legislation, as well as our approach to preventing modern slavery in our
operations and supply chain.
Exploitation: Slavery, servitude or forced or compulsory labour; sexual exploitation including but
not limited to prostitution and sexual offences against children; the removal of organs unless duly
authorised by the competent authorities; the securing of services or other benefits/advantages
by force, threat or deception; and the securing of services by children or physically or mentally ill
or disabled persons, where it is reasonable to expect, that someone would have refused them,
but for their vulnerability.
Human trafficking: The organisation or facilitation of the travel of another person for the purpose
of exploiting that person. It is irrelevant, whether this person has consented to the journey or not.
The exploitation does not have to have actually taken place.
Modern slavery: This includes slavery, servitude, forced and compulsory labour and human
trafficking.
Scheer IMC is committed to eradicating modern slavery and human trafficking in all forms. We
will not tolerate any form of forced labour, child labour, bonded labour, or human trafficking within
our operations or supply chain. We are committed to ensuring that our business and supply chain
partners share our values and adhere to the highest ethical standards.
The prevention, detection and reporting of modern slavery in any part of our business or supply
chain is the responsibility of everyone, who works for Scheer IMC or is under the control of the
Scheer IMC company. This policy applies to all Scheer IMC employees, directors, officers,
consultants, contractors, agents, representatives, business partners, sponsors, interns, casual
workers and student workers.
Senior Management: Senior management is responsible for overseeing the implementation of
this policy and ensuring compliance with the Modern Slavery Act. They will provide leadership,
resources, and support to promote a culture of transparency and accountability.
Employees: All employees are responsible for familiarising themselves with this policy and
conducting themselves in accordance with its principles. Employees should report any concerns
or suspicions of modern slavery or human trafficking promptly and confidentially to their
manager or the designated point of contact.
Supply Chain Partners: We expect our suppliers, contractors, and business partners to share our
commitment to preventing modern slavery and human trafficking. We will work collaboratively
with them to assess and address risks within our supply chain and promote compliance with the
Modern Slavery Act.
We will conduct due diligence assessments to identify and mitigate the risk of modern slavery
within our operations and supply chain. This includes:
- Assessing the risk of modern slavery in our operations and supply chain, including
geographical locations and industry sectors. - Evaluating our suppliers and business partners to ensure they meet our standards for
ethical conduct and human rights. - Implementing measures to monitor and address any instances of modern slavery or
human trafficking identified.
In the event of a reasonable suspicion of a breach of this policy, the Compliance Office must be
informed immediately. The Compliance Office can be contacted via the e-mail address below,
via the designated ticket in the ticket system, or via the whistleblower system (https://im-c.hinweisgeberschutzsystem.de/).
The same applies if a company of the Scheer Group receives an official notification concerning an alleged involvement in slavery activities.
Alexandra Razmakhaeva, LL.M.
Legal & Compliance Officer
E-mail: [email protected]
The policy is binding on all Scheer IMC employees and is intended to ensure that they are informed of,
and comply with, the obligations and provisions set out herein.
We are committed to continuously improving our efforts to prevent modern slavery and human
trafficking. We will review and update this policy regularly to reflect changes in legislation, best
practices, and emerging risks. We will also monitor our performance and seek feedback from
stakeholders to inform our ongoing efforts.
Scheer IMC will maintain accurate records and documentation to demonstrate compliance with
the Modern Slavery Act and all other pertinent legislation. We will submit an annual statement
detailing our efforts to prevent modern slavery and human trafficking, as required by law. This
statement will be approved by senior management and published on our website.
Scheer - imc is committed to taking a proactive and robust approach to preventing modern
slavery and human trafficking. We recognise that eradicating these abuses requires
collaboration, transparency, and sustained effort across our organisation and supply chain. By
adhering to this policy and working together with our stakeholders, we can make a meaningful
contribution to ending modern slavery worldwide.
This policy serves as a framework for addressing modern slavery within the organisation and
promoting compliance with the Modern Slavery Act and all other pertinent legislation.
