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Corporate Governance & CSR

Modern Slavery and Human Trafficking

Hesco Bastion Limited (‘Hesco’) is committed to carrying out its business with integrity, ethically and responsibly, which includes ensuring that slavery and human trafficking are not taking place within any part of its business or supply chain. This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and explains the measures Hesco has taken to prevent slavery and human trafficking in its business and supply chain during the last financial year ending 31 December 2018.  It has been approved by the Board of Directors.

Hesco’s Main Business

Hesco designs, develops and manufactures a range of protective structures and barriers, working from its UK manufacturing facility. The site operates a Quality Management System accredited to ISO 9001:2015. Our products are used across the globe and customers are predominantly large international businesses, national governments, humanitarian and peacekeeping NGOs. Our products offer protection from natural threats such as flooding, as well as protecting people and assets in conflict zones or where there is a significant terrorist threat. 

Our supply chain:  We have a small, specialist, and very long established supply chain, with approved key suppliers being based in Europe and the USA. Relationships are strengthened through regular and ongoing supplier approval visits, so that any who are operating or sourcing from high risk countries, where modern forms of slavery are prevalent, can be quickly identified and audited.   

Our Policies in relation to Slavery and Human Trafficking

Hesco has maintained policies and procedures to ensure that all business is conducted in a transparent, ethical, and responsible manner, thus remaining compliant with the Modern Slavery Act 2015. Our policies and procedures include:

  • Modern Slavery and Human Trafficking Policy
    • This policy sets out Hesco’s zero tolerance stance and explains Hesco’s procedures to ensure modern slavery and human trafficking is not taking place in its business and supply chain, including how suspected breaches can be reported.
  • Supplier Code of Conduct
    • The code of conduct sets out Hesco’s high expectations of its suppliers (and their own suppliers), and imposes a requirement to comply with our Modern Slavery and Human Trafficking Policy.

Other existing policies such as the ones below are designed to ensure compliance to high ethical standards of behaviour throughout the organisation, fair treatment of all colleagues, and an open culture where any concerns can be raised with Management:

  • Anti- Bribery and Corruption Policy;
  • Whistleblowing Policy
  • Grievance Policy

During 2018, Hesco has supplemented its policies with groupwide policies and groupwide compliance training.

The following groupwide polices were implemented in 2018:

  • Anti-Slavery and Human Trafficking Policy;
  • Anti-Bribery and Corruption Policy;
  • Third Party Representatives Policy;
  • Whistleblowing Policy

As part of the Whistleblowing Policy, Hesco has introduced a confidential hotline and online reporting system to ensure an easy means of reporting any policy violations.

Our Due Diligence Processes

Following the publication of the Modern Slavery Act, Hesco has introduced further due diligence on the supply chain as part of the approval process leading to preferred supplier status.  We continue to consider where our business and supply chain is most at risk.

  • Site visits to preferred suppliers’ premises have been increased to ensure visual checks on workers’ conditions are carried out. This includes any overseas suppliers.
  • We request that key suppliers provide their policies on anti-slavery and human trafficking, as well as any other policies that show they operate with clear ethical responsibility towards their workforce, and comply with legislative requirements, for example on pay, equal treatment and working conditions.
  • Hesco does not support or knowingly deal with any business involved in slavery or human trafficking. We will not work with any company in breach of the Supplier Code of Conduct, or identified as having slavery and human trafficking in its business or supply chains.

During 2018 we requested that our key suppliers acknowledge and agree to our Supplier Code of Conduct.

Our Training

Hesco’s in-house legal team and Supply Chain Manager have completed external training on the requirements of the Modern Slavery Act and we will provide further training as required for any other managers involved in the supply chain function to ensure they can evaluate the risks and recognise signs of modern slavery and human trafficking.

During 2018 we rolled out online training modules, which ensured that each individual employee undertook mandatory compliance training.

Looking Ahead

Following a review of the effectiveness of the steps we have taken this year to ensure there is no slavery or human trafficking in our supply chains we intend to continue to critically evaluate the policies we have put in place to prevent slavery and human trafficking taking place in its business and supply chain. We will report and act on any reports or notifications from staff or external authorities, including prosecutions or criminal charges, and thus ensure no forms of compulsory labour and human trafficking take place in our business and supply chain.  Throughout the next year, we shall continue to engage with our preferred suppliers to ensure compliance with our Supplier Code of Conduct.

Download PDF: Modern Slavery and Human Trafficking Statement 

 Signed Kevin Lyons

Signed Kevin Lyons,
Chief Operations Officer
Hesco Bastion Limited

Download PDF