Hanwha Techwin Europe Ltd.
Modern Slavery Act Statement
Financial Year 2018-2019
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 2018.
Business Structure and Supply Chain
Hanwha Techwin Europe Ltd.’s principal activities are the import and distribution of Hanwha branded surveillance hardware and software. Our operations are predominantly pan-European and also in Turkey.
Hanwha Techwin Europe Ltd. is 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 1,791 employees across 19 countries, where site activities range from production and sales to design and research, as well as holding regional head offices worldwide. For the most part, products distributed by Hanwha Techwin Europe Ltd. have been purchased from Hanwha Techwin Co. Limited or one of its subsidiaries.
Approximately 84% of Hanwha’s products are manufactured at Hanwha-owned facilities, and we work diligently to provide world-class working conditions throughout our manufacturing network and comply with local laws and regulations in all regions in which we operate.
Our Code of Conduct
A Code of Conduct is a set of standards on social, environmental and ethical issues, and this Code is designed to express our commitment to conducting business in an honest, fair and transparent way. It is 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. Hanwha Techwin Europe Ltd are commited to conducting business in an honest, open, fair and transparent way. Our Senior Management team ensures that our 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 including Hanwha Techwin Europe Ltd. will collaborate or associate with any suppliers who have failed to comply with basic International Labour Organization (ILO) standards.
Due Diligence Processes and Risk Management
Hanwha Techwin Co. Limited considers the issues and risks covered by the UK Modern Slavery Act and even if they are deemed to be non-existant within our own operations, are well aware that the risks are considerably higher in our supply chain in order to ensure we are working with suppliers that meet our own high standards of operation.
Hanwha Techwin Co. Limited adopts a three-stage process of self-assessments, on-site inspections and third party verifications with any partners with whom they choose to work.
We have dedicated compliance team operating at Hanwha Group level whose sole responsibility is to conduct comprehensive risk analysis reports and ensure compliance across all Hanwha practices including such key matters such as labour management and human rights, health and safety, sustainability, the environment and ethics management. This unit works closely and collaboratively with all relevant business divisions to identify risks and swiftly resolve them.
We actively encourage suppliers to analyse their own internal 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 if necessary, we can provide consultative and investment support.
Our Performance Indicators
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 could possibly occur with our supply chain or within our own places of work. We operate a variety of grievance handling channels (e.g. a hotline as well as both offline and online channels) for both suppliers and employees. Grievance reports are reviewed by the responsible department and informants are notified of proposed solutions. All reported grievances are categorised and their progress tracked with a schedule of completion and outcomes.
Alongside the grievance procedure, Hanwha Techwin Co. Limited operates a whistle-blowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practives within our business or supply chain, without fear of reprisal.
We will know the effectiveness of the steps being taken by our Company to ensure no slavery and/or human trafficking is taking place within our business or supply chain if no reports are received from either the employees who work diligently to uphold our Code of Conduct, or the public or law enforcement agencies to indicate otherwise.
Corporate culture and values, including our Code of Conduct, are vital parts of our induction program for all employees in Hanwha Techwin Europe Ltd.
Hanwha Techwin Co. Limited also provides training to our suppliers to raise awareness of human rights and improve working conditions. We distribute a ‘Code of Conduct Guide’ to our suppliers to ensure that an equal level of principle and policy is adopted by each of them in their daily business activities. The Guide is designed to align our strategies, provide a deeper understanding of our Code and values and provide detailed measures for the integration of sustainability.
Hanwha Techwin Co Limited conducts online training programmes for employees responsible for human resources or supplier management at our production subsidiaries in order to develop and better their understanding of human rights issues. There are also mandatory training programmes circulated to all employees working in our production subsidiaries across the globe, which include our policy and guidelines on human rights.
Hanwha is committed to maintaining a sustainable and responsible supply chain. To continue to ensure that slavery and human trafficking operations do not take place in our supply chain we will persist in working collaboratively with our key stakeholders to refine and improve our policies, procedures and programmes. We will continue to outline steps to tackle these issues in our annual sustainability report and modern slavery statement.
This statement has been approved by the Board of Directors of Hanwha Techwin Europe Ltd.
Tax strategy of Hanwha Techwin Europe
Hanwha Techwin Europe Ltd. are publishing this tax strategy for the 2018 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.
Hanwha Techwin Europe Limited (“HTE”) is a wholly owned subsidiary of Hanwha Techwin Company Ltd (“HTW”), a company incorporated in South Korea, and a member of the Hanwha group of companies.
HTE’s principal business is the purchase of CCTV and security products from its parent and the sale of these products via distribution throughout Europe and Turkey.
HTE is committed to complying with all aspects of UK tax law and practice. Compliance means ensuring the correct amount of tax is paid at the right time and all tax returns are submitted to HMRC in accordance with due dates.
This approach applies to all UK taxes applicable to HTE’s operations including corporation tax, VAT and payroll taxes.
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 & Management of Tax Risk
Ownership of our tax strategy, as with the wider business strategy, rests with Hanwha Group’s board and HTW in general. The day-to-day responsibility for tax rests within HTE, as taxes by their nature are levied on legal entities rather than on the Hanwha Group or HTW as a whole.
HTE and its 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 tax requirements, professional external advice is obtained.
HTE’s Chief Financial Officer is responsible for the company’s compliance with UK tax requirements and for the management of their tax risks. The finance team together with external professional advisors provide support to the CFO in relation to the preparation of tax returns, and observing and implementing changes to UK tax law.
HTW’s Compliance Team in Korea monitor HTE’s tax compliance and tax risk on a regular basis. Any risks thought to be significant are reported to the Board of Directors and to the Audit Committee. CFO provides updates on material tax matters as part of the regular updates to HTW and Hanwha Group’s board.
HTE has a conservative approach to taxation issues and seeks to ensure its tax affairs reflect the regulatory, legal and commercial environment in which its business operates. All decisions are taken after careful consideration of all the issues and potential impacts. HTE does not employ aggressive interpretation of the tax law, or partake in tax avoidance schemes which are contrary to the intention of the law.
The external tax advisers are consulted to provide advice on commercial transactions to identify risks and ensure tax compliance.
HTE’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 the IT systems.
HTE is the representative of HTW’s business interests in the UK and Europe. HTE receives tax advice from our tax teams in Hanwha Group, HTW, and country level comprising individuals 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 compliant with UK tax requirements at all times. From time to time we engage external tax advisers to provide specialist expertise, to provide second opinions on significant transactions, and to help us with insight on industry practice. This situation is closely monitored both by HTE’s Chief Financial Officer and finance team, and HTW’s compliance team.
Interaction with Tax Authorities
We understand our tax affairs are complex, given the range of taxes that apply to our businesses and the cross-border dimensions that come from being an international group.
HTE has an open and transparent relationship with HMRC and endeavours to communicate with honesty, integrity and in a co-operative and professional manner, and enhancing mutual trust and cooperative relationships. If a situation arises requiring clarification or interpretation of a complex tax matter, HTE will aim to work pro-actively with HMRC to ensure HTE adopts the most appropriate treatment.
Bob (H.Y.) Hwang PhD