Bericap UK Ltd

Modern Slavery Statement

Policy statement

Modern Slavery can take many forms including the trafficking of people, forced labour, servitude, slavery, and any other deprivation of a person’s liberty to create a personal or commercial gain. Bericap UK takes a zero-tolerance approach to modern slavery. We are committed to ensuring that modern slavery or human trafficking plays no part in our supply chain or in any part of our business.

Bericap UK considers that modern slavery encompasses:

  • human trafficking
  • forced work, through mental or physical threat.
  • being owned or controlled by an employer through mental or physical abuse of the threat of abuse.
  • Being dehumanised, treated as a commodity, or being bought or sold as property.
  • Being physically constrained or having restrictions placed on freedom of movement.

Bericap UK undertakes due diligence when considering appointing new suppliers. We set out clear expectations and evaluate the modern slavery and human trafficking risks of each new supplier. Our policies, procedures and code of conduct are pursuant to section 54(1) of the Modern Slavery Act 2015, and we review our Modern Slavery policy every year.

Bericap UK Limited is a wholly owned subsidiary of the German private family owned Bericap Group engaged in the manufacture of caps and closures for the purpose of packaging customer products.

We expect our staff, contractors, suppliers, customers, and other business partners to report, without fear of retaliation, any concerns and for Bericap UK management to act upon them.

This policy applies to all persons working for Bericap UK, on our behalf, or in any capacity associated with our business. This includes, but is not limited to:
All employees
Directors
Officers
Agency Workers
Seconded Workers
Volunteers
Interns and work experience
Agents and contracted staff
Consultants and advisors
Business Partners

This policy does not form part of any employee’s contract of employment, and we may change or amend it any time.

Responsibility

The Managing Director, with the support of the Board of Directors, and the site Senior Management Team have overall responsibility for ensuring this policy complies with our legal and ethical obligations, including any person or organisation under our control.

Our HR, Quality, and Supply Chain Management have shared primary and day-to-day responsibility for implementation, continually measuring its use and effectiveness. All internal audits and controls are undertaken by these individuals and concerns should be reported directly to them.

Management throughout the business are responsible for ensuring the policy is cascaded and complied with, including regular training given to staff, especially those involved in the management and appointment of suppliers and subcontractors.

Compliance
  1. You must read, understand, and comply with this policy.
  2. Prevention, detection and reporting of any event or instance which may be deemed as modern slavery, in any part of our business or supply chain is the responsibility of anybody appointed to work on behalf of the company, directly employed or otherwise appointed.
  3. You must notify your line manager, HR/H&S department immediately if you believe or suspect a conflict of this policy has or may occur.
  4. You are encouraged to raise concerns as soon as possible and will be appropriately protected in a confidential, anonymous nature for doing so.
  5. If you are unsure of a suspicious event constitutes modern slavery, please raise it with your line manager immediately.
  6. Your line manager is responsible
Communication

Some of our projects require subcontract organisations to carry out work and services on our behalf. We are committed to ensuring that slavery and human trafficking play no part in our supply chain or any part of our business.

As part of our initiative to identify and mitigate risk:
1. We create long-standing relationships with our suppliers and subcontractors and make clear our expectations of business conduct.
2. We have in place systems to encourage the reporting of concerns and the protection of whistle blowers.
3. Our policy, code of conduct and ethical trading policy form part of our induction process for all individuals who work for us at any location or project site, this includes initial employee inductions and site inductions.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff.

Breaches

Any employee or appointed person who breaches this policy will face disciplinary action.
Employees or appointed persons may be suspended immediately pending further investigation.
We may terminate relationships with employees, individuals and organisations working on our behalf if they are shown to have breached this policy.

Review

This policy shall be reviewed on an annual basis and amended as and when necessary to reflect changes in relevant legislation.
During 2026 our focus will be to maintain training. We will ensure all employees new and existing complete applicable training to their role, and our code of conduct and ETI base code are communicated to support in the compliance of this statement.

Jason Evans
Managing Director
Bericap UK Limited
Date of current issue: February 2026
Date of next review: February 2027

Bericap UK Tax Strategy – Period ending 31 December 2023

In compliance with section 161 and paragraph 19(2) of schedule 19 Finance Act 2016, Bericap UK Limited is publishing its UK tax strategy for the year ending 31 December 2023. Bericap UK Limited is a sole UK company, part of the wider Bericap group, headquartered in Germany.
This tax strategy applies to all UK taxes applicable to the company. It will be reviewed annually and updated where appropriate. The tax strategy is effective from 1 January 2023 for the year ended 31 December 2023.

The Bericap UK overall tax strategy is to:
  • Comply with all applicable tax laws, rules, regulations, reporting and disclosure requirements;
  • Act independently whilst remaining consistent with the Bericap group’s strategy and mission;
  • Use incentives and reliefs to minimise the tax costs of conducting its business activities, but not for purposes which are contrary to the intent of applicable regulations;
  • To consider tax impacts as part of decision making processes;
  • Apply professional diligence and care in the management of all risks associated with tax matters, and employ appropriate governance and assurance procedures.
Risk management

Bericap UK Limited has a finance team which takes responsibility for the company’s tax processes, reporting to the company’s finance director. The finance team engages professional tax advisors to ensure that the company meets its compliance and filing obligations.
The Bericap group has a head office finance function based in Germany. The group has a decentralised operating model and accordingly the UK finance team acts with autonomy in relation to tax risk management, but will refer to this group team, including the group finance director where there are tax matters of a group wide significance beyond UK-only compliance considerations.

The finance team will also use professional tax advisors to advise on other specialist tax matters, as and when required. This ensures that the company is provided with the specialist advice necessary to meet its UK tax compliance obligations, and enables the company to identify and manage tax risk.

Attitude towards risk

Bericap UK Limited’s appetite for tax risk is low and it sees compliance with tax legislation as key to managing its tax risk. The company has processes in place to evaluate tax risks as part of its decision making processes. Potential areas of tax risk are identified by the company finance team and/or professional tax advisors during the course of the tax accounting processes. Any areas identified are taken into consideration in the conclusion of wider business decisions.

Tax planning

Bericap UK Limited does not undertake tax planning. It uses the assistance of its advisors solely for meeting its compliance obligations in accordance with the law, and advising on available reliefs. It will claim available allowances, deductions, reliefs, incentives, exemptions and credits where it is beneficial to do so, in line with the intended purpose of such reliefs.

Relationship with HM Revenue & Customs (HMRC)

Bericap UK Limited aims to have an open and professional relationship at all times with HMRC. It uses its professional tax advisors as agents in relation to corporation tax, who deal with HMRC on the Company’s behalf. The Company does not have a Customer Compliance Manager at HMRC and is not subject to the Business Risk Review process or risk rating. If the company were subject to this process, then the company would seek to achieve a ‘low risk’ rating.
It is the company’s policy and practice to make fair, accurate and timely disclosure in correspondence and returns, and to respond to queries and information requests in a timely fashion.