WE Soda Limited Statement on Modern Slavery
For the financial year ended 31 December 2025
Introduction
WE Soda is committed to preventing slavery and human trafficking in our business and our supply chain. In line with Section 54 of the Modern Slavery Act 2015, our Modern Slavery Statement sets out the steps we have taken to prevent, detect and respond to slavery in our business and throughout our supply chain during the year ending 31 December 2025.
Our Business
Organisational structure
Since starting production in 2009, the WE Soda Group has developed into a market leader in the manufacture and supply of natural soda ash.
Headquartered in London, UK, the company produced over 9 million metric tonnes of sodium carbonate (soda ash) and sodium bicarbonate in 2025 from four production facilities in Türkiye and the USA. In February 2025, they acquired Genesis Alkali, adding 4.3 million metric tonnes of capacity from two facilities: Westvaco (a conventional dry-ore trona mine) and Granger (a solution mining operation).
The company also operates two port handling facilities: Denmar in Türkiye, which provides full control of bulk product exports and supports a 'hub and spoke' distribution network across Europe, and the T4 export terminal in Portland, Oregon, with a capacity of ~4.0 million metric tonnes. Together, these make the company the largest supplier with the broadest reach in the global seaborne soda ash market, enabling them to serve every customer in every end-market through the most resilient supply chain.
Our total workforce at the end of December 2025 was over 2,500 full time employees.
In January 2019, WE Soda appointed a Board of Directors to manage the Group and provide leadership and oversight of its operations. In early 2023, our Sustainability Committee was constituted and has formal responsibility for ensuring that our business operates sustainably, including the oversight of our corporate social responsibilities. More recently we enhanced the size and strength of our commercial and logistics teams thereby enabling us to efficiently serve and meet the needs of our customers worldwide.
Our purpose
Our purpose is to responsibly produce essential ingredients for a sustainable future. The principal activity of our Group is the extraction and processing of trona ore to produce sodium carbonate (soda ash) and sodium bicarbonate. Soda ash is an essential ingredient used in the manufacture of a wide variety of everyday products such as glass and powdered detergents and, more recently, it has become an important energy transition material used in the manufacture of PV solar panels and the rapidly expanding lithium-ion battery market for electric vehicles.
Operating Sustainably
We publish an Integrated Annual and Sustainability Report each year in April which details our strategic approach to operating sustainably. Our inaugural Sustainability Plan also outlines our longer-term goals and targets, including our approach to ensuring we are operating responsibly, such as collaborating with or gaining certification from third parties that assure human rights and labour within our own organisation and the higher risk links in our supply chain.
We are very proud that the WE Soda Group was awarded a Platinum medal by EcoVadis for the second year in a row in 2025. EcoVadis, an internationally renowned sustainability ratings provider, focus their assessments on key sustainability performance indicators grouped into four themes: Environment, Labour & Human Rights, Ethics, and Sustainable Procurement.
The criteria used for their assessments are based on international sustainability standards such as the Global Compact Principles, the International Labour Organization (ILO) conventions, the Global Reporting Initiative ("GRI") standard, the ISO 26000 standard, and the CERES principles.
The Labour & Human Rights pillar focusses not only on internal labour practices but also on human rights (including child and forced labour) and human trafficking within our supply chain.
Being awarded a Platinum medal, places us in the top 1% of basic chemicals companies assessed by EcoVadis globally. Our Group scored strongly above average in all four pillars. Obtaining a rating with EcoVadis provides our stakeholders with third party assurance that we are continuously striving to operate in a responsible manner.
We are setting ourselves the goal of working to the highest independent sustainability standards in the mining sector by seeking to achieve the highest scores from the Initiative for Responsible Mining Assurance (IRMA) scheme, a mining standard and assurance scheme that includes human rights.
Our objective is to achieve transparency level IRMA certification within the next two years across our four sites. Our target is to achieve IRMA 70% by 2030 across our sites. The assessment process itself will help to verify there are no issues in our business, or flag anything which might need addressing. Irma has over 400+ auditable metrics.
Supply Chain
We sell our products to industrial customers in over 80 countries around the world. Our four production facilities in Türkiye, (Eti and Kazan) and USA (Westvaco and Granger), work with over 1,228 suppliers globally which provide our business with many different products and services from inbound raw materials and equipment to the transportation of outbound finished goods and recycling services.
During 2024, we have been working hard to further improve our sustainable procurement programmes. Since 2021, we have been encouraging our suppliers in Türkiye to become registered members of Sedex, the world’s largest data platform for supply chain assessment. Designed to help companies analyse risk in their supply chain, it has enabled us to screen our suppliers, giving us greater visibility into their ethical trading practices and sustainability performance. This uses both Self-Assessment Questionnaires (SAQs) and Sedex Member Ethical Training Audits (SMETA).
In 2025, 58% of our core upstream suppliers in Türkiye (those critical to our production process who we used on a repeat basis and represent approximately 90% of total WE Soda Group spend) were on-boarded to the Sedex platform. This enables us to audit suppliers using self assessment questionnaires submitted to the Sedex platform. On-site supplier visits are made, on a risk-based approach and we collaborate and provide support to help them enhance their own practices.
Our target to achieve IRMA across our sites will provide useful assurance for our own customers and investors. But we are also working with our lime suppliers to help them achieve IRMA certification.
Similarly, those suppliers who supply wood-based products such as pallets and biomass are expected to obtain Forest Stewardship Council (FSC) accreditation, FSC’s principle 2 focuses on Workers’ Rights and Employment Conditions.
Another initiative, which was launched in December 2025, and of which we are pleased to be a founding member, is ResponsibleGlass. More than 50% of the Soda Ash sold goes into the manufacture of glass. Therefore, it is a significant part of our down-stream supply chain. ResponsibleGlass like IRMA and FSC will set the sustainability standard for glass manufacturers and buyers.
Also, during 2024, we appointed experts in sustainable procurement to work with us to develop and implement an enhanced sustainable procurement programme. During 2025 we have been working hard to further improve our sustainable procurement programmes with a focus in Türkiye.
Our Supplier Code of Conduct sets out the criteria and expectations we have of our upstream suppliers in relation to their business ethics, modern slavery and anti-human trafficking commitments and environmental targets.
Our work with Hestia
As part of our corporate social responsibility programme, we have been working in partnership with Hestia since early 2022.
Amongst other essential services, Hestia provides safe houses and outreach support to victims of modern slavery in London. Initiatives which WE Soda have supported have helped hundreds of survivors of modern slavery in our communities rebuild their lives.
We have also sponsored Art is Freedom, Hestia’s annual public art exhibition created by survivors of modern slavery.
Our long-term partnership with WE Soda provides impactful support to survivors of modern slavery, while also working to prevent future harm through awareness-raising. In addition to empowering programmes that help survivors to rebuild their lives after exploitation, WE Soda continues to support Hestia’s Art is Freedom public campaign, which reached over 8 million people in 2025, raising awareness and understanding of modern slavery.
Alison Logier, Director of Modern Slavery Response, Hestia
Learn more about the important work being delivered by the team at Hestia:
Our Policies on Anti-Slavery and Human Trafficking
WE Soda acknowledges that modern slavery is a heinous crime resulting in the abuse of human rights and must be eradicated. We are committed to ensuring there is transparency in our approach to tackling modern slavery within our organisation and throughout our supply chain, consistent with our disclosure obligations under the Modern Slavery Act 2015.
To meet these obligations, we have committed to a number of initiatives which steer our approach to modern slavery compliance.
Our statement and policy on Anti-Slavery and Human Trafficking is communicated to all employees, and furthermore the policy forms part of our Business Ethics training programme and our Employee Handbook.
Both Eti Soda and Kazan Soda renew their ISO26000 Social Responsibility certification annually.
In addition, we conduct an annual third-party audit at our production sites to ensure that no acts of modern slavery are committed within our business.
Our Training Programmes
It is estimated that today around 17,000 people1 suffer from modern day slavery in the UK. Across the world, the number rises to almost 50 million2. 52%3 of forced labour and human exploitation occurs in high to middle income countries.
Our Supplier Code of Conduct, Statement on Business Ethics and other company policies require that our suppliers, employees, contractors and any third parties acting for, or on behalf of, our company do not commit, authorise or be involved in any unethical business practices. These policies set our expectations with regards to third-party management, health and safety, human dignity and labour, and anti-slavery and human trafficking.
WE Soda ensures that all staff are trained to recognise the signs of modern slavery and human trafficking and on a periodic basis employees refresh their knowledge of this important topic. This would include noticing that an individual is providing inconsistent information, does not have their own bank account or is being transported to work at unusual times or in a group with others.
Our training and policies ensure all of our employees are actively aware of modern slavery and their responsibilities to report any concerns whether within our own business or within our supply chain.
Our US business was acquired in February 2025 and as part of the on-boarding process 96% of employees completed a suite of business ethics training modules which included training on Modern Slavery and Human Trafficking.
At the end of 2025 we also worked with Hestia to develop a supplementary Modern Slavery and Human Trafficking Awareness Module. This new training module was launched to staff based in the London office in November 2025. The module was also customised in the Turkish language for colleagues in Türkiye, covering local and regional risks and the training was launched there in December 2025.
Our employees can convey any concerns and report potential violations of our Business Code of Ethics through any of the reporting channels detailed in our Whistleblowing Policy or via our designated we•speakup programme.
Email: wespeakup@wesoda.com
Responsibility for the Policy
The Board of Directors has overall responsibility for ensuring the Group’s policies, systems and controls comply with our legal and ethical obligations, and that all those under our control comply with it.
For and on behalf of WE Soda Group:
Alasdair Warren
Director, Chief Executive Officer
19 June 2025
gov.uk National Referral Mechanism Statistics
antislavery.org
ilo.org
This year, we have also collaborated to deliver bespoke modern slavery awareness training for WE Soda employees in the UK and Türkiye, strengthening knowledge, and action across the organisation, and in the communities we work and live.