Hanwha Techwin Europe Ltd.
Modern Slavery Act Statement
Financial Year 2020
The Modern Slavery Act of 2015, Section 54, requires that businesses operating in the UK publish an annual statement reporting on its practices and efforts taken to prevent slavery and human trafficking anywhere in their own business or their supply chain.
Hanwha Techwin Europe Ltd. Published our first Modern Slavery Statement in May 2017 and since then we have further increased our efforts to ensure that neither slavery nor human trafficking is taking place in our operations and supply chain. Hanwha are committed to improving our practices and recognise that we have a responsibility to take a robust approach to modern slavery and human trafficking within our business.
Hanwha Techwin Europe Ltd. has issued this statement for its financial year ending 31 December 2020.
Hanwha Techwin Europe Limited (“Hanwha”) fully supports the government’s objectives to eradicate modern slavery and human trafficking. We operate under a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships. Equally, we do expect the same high standards from all of our suppliers, customers, partners and contractors, in turn expecting them to adopt the same zero tolerance approach to the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect our suppliers to hold their own suppliers to the same high standards.
Hanwha published our first Anti-Slavery Statement in May 2017, and since then has further increased efforts in our efforts in our commitment to continually review and ensure neither slavery or human trafficking is taking place in our operations, commercial transactions or supply chain.
About Hanwha Techwin Ltd
Hanwha’s principal activities are in the import and distribution of Hanwha branded surveillance equipment and solutions. Our scope of activity sits across all of Europe and also includes Turkey.
We are proud to be part of the Hanwha Group of companies, and a subsidiary of Hanwha Techwin Co. Limited, a company incorporated in the Republic of Korea. Hanwha Techwin Co. Limited employs approximately 1,793 employees spanning 19 countries of operation, where site activities range from production and sales, to design and research, as well as holding regional head offices worldwide.
With around 86% of Hanwha’s range of products manufactured at Hanwha-owned facilities, and as part of a global reach company, we work diligently to provide world-class working conditions for our employees and contractors throughout the manufacturing network, in order to comply with all local legislation and any regulations in effect in our territories of operation.
Hanwha’s Code of Conduct
The Code instilled at the core of our business is based on a set of social, environmental and ethical issues, designed to express our commitment to conducting business in an honest, fair and transparent way and based on the United Nations Guiding Principles on Business and Human Rights, the United Nations Global Compact, the United Nations Declaration of Human Rights and the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work.
Our Senior Management team ensure that the Code of Conduct is regularly reviewed in order to reinforce our commitment to the protection of employees’ human rights, prohibition of child labour and enforcement of involuntary labour and cooperative labour-management relations.
It is our firm commitment that neither Hanwha Techwin Co. Limited, nor any subsidiary thereof to the inclusion of Hanwha Techwin Europe Limited, will collaborate or associate themselves with any supplier who fails the keen set of standards we hold so dear, and as an absolute minimum, the basic International Labour Organisation (ILO) standards.
Due Diligence and Risk Management
Hanwha Techwin Co. Limited carefully evaluates and considers the risks covered by the Modern Slavery Act (2015) and are acutely aware of the dangers of an opportunity for such activity being considerably higher in this type of supply chain. It is because of this that diligent checks are completed and commitments made to ensure we are only working with suppliers that met our own exacting standards of operation, conduct and ethical value.
The company adopts a three-stage process for self-assessment, onsite inspections and third party verification with any partner with whom they elect to go into business for procurement or supply.
A dedicated compliance team operate at the core of Hanwha Group, whose sole responsibility is to conduct comprehensive risk analysis reports and ensure compliance across all Hanwha company practices including such key matters as labour management and human rights, health and safety, sustainability and green procurement and business ethics. This unit works closely and collaboratively with each relevant business division to identify risks and swiftly resolve them.
As a business, we actively encourage suppliers to analyse their own internal practices and risk factors, and as a result improve any identified compliance gaps. Suppliers share information on areas for improvement and proposals for conformity with us, and in turn, we provide support in the form of consultation and investment where necessary and appropriate
Hanwha Techwin Co. Limited has developed a global grievance handling mechanism to identify potential violations of any work environment standards or the infringement of human rights that may occur within our supply chain or within our own places of work. This mechanism has multiple channels of open communication – a confidential hotline, as well as both offline and online channels of safety for both suppliers and employees. Grievance reports are compiled and reviewed by responsible departments and informants notified of proposed solutions for eradication of their concerns. All reported grievances are categorised and their progress tracked with a schedule of completion and an outcome.
The company’s whistle-blowing policy ensures employees can raise concerns about treatment, business practices and risks without fear of reprisal.
The effectiveness of such mechanisms and other steps being taking by the company can be measured by the assurance that no slavery and/or human trafficking taking place within our business operations or supply chain are being reported by either our employees wo work diligently to uphold our Code of Conduct, or the public and law enforcement agencies in place to ensure we hold up to our commitments.
Corporate culture and values, including the Code of Conduct, are vital parts of Hanwha’s induction programme for all employees throughout the Hanwha Group, including Hanwha Techwin Europe Limited.
Hanwha also issues quarterly Compliance programme initiatives to all employees across the business, to get them engaged and vigilant to ethical business practices, providing them with guidance as to how each role in the company can do their part.
In particular, those responsible for activities of human resources and supplier management at the production subsidiaries are provided with regular online training programmes designed to help develop a deeper understanding of human rights and their application to our business. A mandatory training programme is circulated to all employees working on our production sites across the globe to promote our guidelines on human rights and labour regulations.
Hanwha Techwin Co. Limited provides active training to suppliers to raise awareness of human rights and working conditions. A “Code of Conduct Guide” is issued to ensure an equal footing and understanding of the principles and policies to be adopted by each in their daily business activities – ensuring our expectations are clear and our strategies and goals aligned to achieve a deeper understanding of the Code and measures for the integration of sustainability.
As we hope can be seen through our practices, as a business with a global reach and an important duty to uphold, Hanwha is committed to maintaining a sustainable and responsible supply chain. We will continue to take every step necessary to continue the eradication of slavery and human trafficking in our business operations and persist in working collaboratively and positively with our key stakeholders to refund and improve policies, procedures and programmes, tackling our actions and responses in our annual sustainability report and anti-slavery statements.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. It constitutes our company’s slavery and human trafficking statement for the financial year ending 31st December 2020, and outlines the steps we have taken as an organisation to assess our operations and supply chain and mitigate any risk of slavery and human trafficking. This statement has been approved by the Board of Directors of Hanwha Techwin Europe Limited.
Tax strategy of Hanwha Techwin Europe
Hanwha Techwin Europe Ltd. are publishing this tax strategy for the 2021 financial year to comply with their duty under paragraph 16(2) Schedule 19 of the UK Finance Act 2016.
We (Hanwha Techwin Europe) act responsibly in all out tax matters, recognising the importance of paying the right amount of tax. We take an objective view of the generally understood interpretation of the relevant laws and regulations. We seek to build constructive relationships with tax authorities in the UK and provide transparent disclosure to ensure that all our stakeholders are well informed about out tax matters.
This statement sets out the UK Tax Strategy of Hanwha Techwin Europe Limited. The publication of this statement is regarded as fulfilling the company’s obligation under Paragraph 19(2), Schedule 19 of the Finance Act 2016.
As part of a multinational company, Hanwha Techwin Europe Limited (“Hanwha”) is aligned with and follows the guiding principles and Code of Conduct of the Hanwha Group.
Hanwha act responsibly in our tax strategy and strategic objectives, establishing a clear and unequivocal approach to all aspects of tax reporting and compliance.
This strategy is owned and approved by the Board of Directors of Hanwha Techwin Europe Limited and sets out the companies general tax arrangements as well as the policy and approach to tax risk management, attitude to tax planning and working closely and collaboratively with the HMRC.
Tax Strategy Statement
The company is committed to compliance with all UK tax laws, regulations and disclosure requirements, recognising the importance of paying the right amount of tax at the right time, filing complete and accurate returns on a timely basis and seeking to utilise any available tax reliefs and incentives, where available, in a manner which is consistent with the government’s policy objectives as well as our own values and Code of Conduct. We seek to build constructive relationships with tax authorities in the UK and provide transparent disclosure to ensure that all our stakeholders are well informed about out tax matters.
We endeavour to contribute to the national economy and social development through improving productivity, job creation, faithful tax payment, and making contributions to society.
Governance and Management
The overall responsibility for the company’s tax strategy rests with the Board of Directors for Hanwha Techwin Europe Limited and our parent company Hanwha Techwin Co. Limited, with day to day management of tax affairs undertaken by the Finance department.
External advisers are engaged to provide additional expertise where it is considered appropriate.
Hanwha and our parent company share a low risk approach to tax governance, and adhere to internationally accepted laws and regulations. If a risk is identified either in relation to compliance or the understanding of complex requirements of taxation require it, external advisers are engages to provide additional expertise where it is considered appropriate.
Hanwha Techwin Co. Limited have a dedicated compliance team who acutely monitor Hanwha’s tax compliance status on a regular basis. Any risks identified through this process and thought to be significant are reported immediately to the Board of Directors and to the Audit Committee. It is the responsibility of the Chief Financial Officer at Hanwha to provide updates on material tax matters as part of a continual process of reporting to our parent company and to the board of Hanwha Group, of which Hanwha is proud to be a part.
Hanwha does not engage in tax planning that does not support a genuine commercial activity, nor does it participate in artificial tax avoidance schemes to reduce its tax liabilities. Our approach is conservative, seeking to ensure our practices reflect the regulatory, legal and commercial environment in which our business operates. Any decisions made are taken only after careful consideration of all risks, opportunities and impacts.
Tax Risk Management
Hanwha’s operations are closely linked with that of its parent company, in particular through the purchase of goods for resale, product development and shared services such as IT systems. We are their operative and representative in the UK and across Europe.
We take a responsible approach to managing our tax affairs, and as a result receive tax advice from authorised employees working at the Hanwha Group, our parent and at each country level with a mix of industry and business knowledge and subject matter expertise, in order to ensure any tax implications of these operational arrangements such as transfer pricing, are adequately addressed to ensure both companies are compliance with UK tax requirements at all times.
Our risk strategy follows the same principles that governs all our business operations and risks, including the consideration of reputational and other non-financial risks. By being tax compliant, the company aims to minimise our risk.
Relationship with Tax Authorities
We understand that tax affairs are complex, given the range of taxes that apply to our international reach, with cross-border dimensions that come hand in hand with our multinational group.
The company maintains and open and transparent relationship with the HMRC and endeavours to communicate with honesty, integrity and in a collaborative and co-operative professional manner, enhancing mutual trust through the provision of full and accurate information. If a situation arises requiring clarification or interpretation of a complex taxation matter, we aim to work proactively with the HMRC to ensure appropriate treatment and increased compliance.
This statement has been approved by the Board of Directors of Hanwha Techwin Europe Limited.
Section 172(1) Statement
Companies (Miscellaneous Reporting) Regulations 2018
The Companies (Miscellaneous Reporting) Regulations 2018 applies to accounting periods beginning on or after 1st January 2019. It requires directors to explain how they considered the interest of key stakeholders and the broader matters set out in section 172(1) (A) to (F) of the Companies Act 2006 (‘S172’) when performing their duty to promote the success of the company under S172.
This S172 statement explains how the directors:
- have engaged with employees, suppliers and others; and
- have had regard to employee interests, the need to foster the company’s business relationships with suppliers, customers and other partners, and the effect of that regard, including on the principal decisions taken by the company during the financial year.
The S172 focuses on matters of strategic importance to the company and the level of information disclosed is consistent with the size and complexity of the business.
The Likely Consequences of Any Decision in the Long Term
The directors understand the business and the dynamic environment in which it operates. They appreciate the necessity to consider the long term consequences of their decisions not only on the company but its stakeholders.
The company’s key values are:
- Challenge – Pursue excellence through change and innovation by breaking away from complacency
- Dedication – Treasure the relationships with colleagues, company, and customers and commit to achieving a greater goal
- Integrity – Stick to principles, be impartial and take pride in doing so
The directors consider that the key to long term success is by adhering to these key values when making decisions, and thus strengthening the brand’s reputation with its stakeholders. They understand that sustained growth is dependent on their relationships with their stakeholders and the strong reputation of its brand.
By applying the company’s three key values and considering the long term consequences of their decisions, the directors expect to continue to add value to the company.
The Interests of Company’s Employees
The directors recognise that employees are fundamental to the business and the delivery of its strategic ambitions. The success of the business depends on attracting, retaining and motivating employees, by ensuring that the company remains a responsible employer, from pay and benefits to health and safety. The directors factor the implications of decisions on employees where relevant and feasible.
The company’s policy on recruitment is based on the ability of a candidate to perform the job. Full and fair consideration is given to applications for employment from disabled people where they have the appropriate skills and abilities to perform the job. All necessary training and assistance is given to enable disabled employees to perform their duties. If employees become disabled during their employment, consideration will be given to retraining and redevelopment.
During the financial year monthly information bulletins were sent to all employees giving information of matters that were likely to concern them. Weekly management meetings were also held giving managers the opportunity to share the views of their staff regarding decisions which were likely to affect employees‘ interests. There is no employee share scheme at present.
In addition during the weekly management meetings information was shared regarding the financial performance of the company, and the general economic and market factors which were affecting the business. The managers were encouraged to share this information with their teams.
The directors engaged with employees throughout the year by means of attending the weekly management meetings described above. Also, a bi-annual newsletter from the managing director was sent to all employees giving details of the financial performance and the economic factors concerning the business, together with news of any key decisions and developments proposed by the company.
The Need to Foster the Company’s Business Relationships With Suppliers, Customers and Others
Delivery of the company’s strategy requires strong relationships with all key stakeholders including suppliers, customers, employees and regulatory bodies. Key stakeholders are identified as those having the most influence over the success of the business. The company promotes the spirit of trust and loyalty and the application of its three key values of Challenge, Dedication and Integrity to each of these relationships. The directors receive information and reports from all key departments within the business on a range of subject including product and supplier contract management, and project opportunity and customer contract management.
The company’s sales teams have direct contact with the customers and they gather feedback and information about customer needs and requests, which are turned into Voice of the Customer (VOC) reports. These VOC reports are taken into consideration when planning and developing products. In addition to this our managing director visited key customers throughout the year to discuss business plans and strengthen business relationships.
We are in constant contact with our suppliers to discuss current demand, delivery dates and possible product developments. The directors realise that good relationships with its suppliers is of vital importance to the business.
The directors took regard of customer, supplier and other interests when making the following principal decisions during the financial year.
The Impact of the Company’s Operations on the Community and the Environment
Our directors are aware of the current concerns regarding the impact of business on the environment. As purely a distribution company our operations do not directly have a significant impact on the community or environment. Our products are sourced from our headquarters in Korea. They have implemented sustainable management practices on the environment, safety, health, energy and greenhouse gas issues under the guidance of the Hanwha Eco-institute. Locally, the company have reduced waste at their European headquarters by introducing a recycling policy for waste paper, batteries and computer toner cartridges, and by switching to a renewable energy supplier.
The Desirability of the Company Maintaining a Reputation for High Standards of Business Conduct
It is important to the company to maintain its spirit of trust and loyalty. The directors periodically review the company’s approach and policies regarding ethics and compliance, modern slavery, GDPR and cyber security, to ensure that its high standards are maintained within the business and its business relationships. The key values of challenge, dedication and integrity are promoted throughout the workplace to highlight the behaviour that the company expects from all employees. A whistleblowing policy is in place so that employees can report any conduct that does not comply with the company’s high standard of business conduct.
The Need to Act Fairly as Members of the Company
After considering all relevant factors, the directors consider which course of action best enables delivery of its long term strategy, taking into consideration the impact on stakeholders. In doing so, the directors act fairly between the company’s members but in doing so this means that certain stakeholders’ interests may not be fully aligned.
The directors took regard of stakeholders interests when making the following principal decisions during the financial year:
- 2019 Business Plan – When approving the company’s business plan for the year the directors took regard to the company’s vision of providing premium security products with high performance, high resolution and high stability to create new social values of safety and reliability, and working for customer trust, and respect from the people who live in communities where they operate.
The review included engagement with key stakeholders including management from the company’s European branch offices who provided information about their local customers’ requirements. The directors engaged with suppliers and key partners, and reviewed recent regulatory and government guidelines, to ensure the plan’s effectiveness to enhance cyber security and provide improved technology and features for their products. It considered its operations effects on local communities and the environment with a view to how the plan could provide improvements.
The directors also reviewed information regarding the organisational structure and employees, with particular attention to salaries, employee benefits, incentives, health, safety and training.
Feedback was obtained from the company’s sales managers concerning the introduction of a new improved sales employees’ incentive scheme, and all mangers were consulted regarding the setting of key metrics against which all employee bonuses were to be calculated for the year. The metrics were discussed at length to ensure they would motivate and support the correct culture within the business, while also aligning with the company’s strategy.
The directors concluded that the final business plan for 2019 underpinned the long term strategy for the company, while also taking into account different stakeholder views, realising that not all stakeholders views can or will completely align with the company’s plan.
- Closing of the Russian representative office – The decision was taken in 2019 to close the company’s representative office in Russia. Before taking the decision the directors considered the impact that it would have on the company’s stakeholders.
Responsibility for the sales in Russia had previously been transferred to another Hanwha subsidiary, so it was thought that there would be no effect on customers. Our Russian employees were consulted about the closure, and it was mutually agreed to transfer their employment contracts including all outstanding holiday allowances and benefits to the Hanwha Corporation subsidiary who had taken over responsibility for the sales in Russia. It was also decided that supplier and key partner contracts would also be transferred directly to the other Hanwha Corporation subsidiary.
Following the review, the directors concluded that the closure of the company’s Russian representative office would provide better management of the Russian sales region with minimal effect on the company’s stakeholders.