Modern Slavery and Human Trafficking Statement
Introduction from the Executive Chairman
We are committed to improving continuously our existing practices to combat slavery and human trafficking. We will study and follow Government reports and guidance, particularly the Home Office 2017 “Transparency in Supply Chains- A practical Guide”, We will also keep under review and amend our trading documents and practices to (i) help identify risk, and (ii) procure appropriate commitments from customers and those in our supply chain.
We are the parent company of the Hexadex group of companies (Group). The Group has over 750 employees worldwide and operates in Europe, North and Latin America and Asia.
The Group has a global annual turnover of circa £80M.
Our business operates through four active subsidiary companies, the boards of directors of which have each adopted this statement. The subsidiaries are:
- Teconnex Limited (CRN: 1447529), a manufacturer of clamps and fasteners which operates from the UK ( as itself and also via a subsidiary, Bellows Technology Ltd, CRN: 076003963) and via a Joint venture company based in Honk Kong with a wholly owned subsidiary in mainland China, also via a subsidiary in Mexico and shortly another in Romania.
- Eminox Limited (CRN: 1349209), a manufacturer of exhaust and emission control systems for commercial vehicles based in the UK but with a global customer base ; Eminox has recently closed branches in Europe with a view to replacing the sales activity there with distributors and has also recently concluded a joint venture operation in China.
- Ceramex Limited. (CRN: 05202141) which cleans diesel particulate filters used on both commercial vehicles and passenger cars; it is based in the UK but also operates via a joint venture mechanism in the states of Delaware and Missouri each a state of the United States of America. An additional joint ventures in Japan has been established during the year.
- Hooton Engineering Limited (CRN: 04125393) a fabrication business specialising in stainless steel products and systems.
Our supply chains and customers
Our supply chains predominantly originate in Europe, where raw materials and proprietary components are purchased from suppliers of repute. Our supplier evaluation procedure requires audit and approval of potential new suppliers before commencement of business. During 2016, we introduced revised supplier audit procedures to ensure that all new suppliers (regardless of turnover) either agree to comply with the provisions and spirit of the 2015 Act, or if smaller than that by which a statement is mandatory, to nonetheless adopt and ensure best practice. During 2017, we have suggested to our customers who impose compliance obligations under the Act on us contractually that these provisions should be reciprocal. Supply chain performance and effectiveness is measured constantly with re- audit and corrective actions being applied as and when required.
Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We will be particularly vigilant to watch for and report any evidence of labour abuse of eastern Europeans or Mexicans, potentially the greatest risk in our operations.
Due diligence processes for slavery and human trafficking
To identify and mitigate risk we will aim to put in place and maintain systems to:
- Identify and assess potential risk areas in our supply chains and customer base.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
- Protect whistle blowers.
Supplier adherence to our values
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a supply chain compliance programme which consists of issuing conditions of purchase requiring counterparties to confirm their own compliance with the provisions of the Modern Slavery Act 2015, and to dealing only with organisations whose ethics we believe after appropriate due diligence enquiry reflect our own.
To ensure an appropriate level of understanding about the risks of non-compliance with modern slavery and human trafficking legislation and in our supply chains and business, we have identified, and will aim to provide, training to relevant staff engaged in or about procurement personnel or accounting activities.
We will conduct a peer review to benchmark best practice and to review and incorporate where appropriate guidance from organisations such as the United Nations and Business and Human Rights Resource Centre. Perhaps working in conjunction with other manufacturers in related industries, we need to find ways in which operation of the policy (as opposed to devising and implementing it) becomes active second nature.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 31st December 2017.
Director, date: 19th December 2017