INTRODUCTION FROM THE CHIEF EXECUTIVE
We are committed to improving our practices to combat slavery and human trafficking. Since the establishment of the Company, one of the key areas of focus has been how we conduct business everywhere we operate. This has not just been from a minimum compliance perspective but from asking the question, “What kind of Company do we want to be?” The answer to that question is that we want to be a Company with the highest standards of ethical behaviour and a real and demonstrable commitment to ethical behaviour. We have developed and issued a Code of Conduct which applies to all our people have a spread of training including in relation to modern slavery, and have an ethics hotline.
ORGANISATION’S STRUCTURE
We are a global provider of advisory and consultancy services in the construction, engineering and industrial sector. We are the parent company of the HKA Global Group of Companies (Group). The Group has over 1,000 employees worldwide and operates in a number of countries, which are all listed on our website.
OUR BUSINESS
Our business is organised into five business units, each representing the Group’s activities in a continental or geographic region. Our business areas are the Americas, Europe, Africa, Middle East & Asia, and Oceania.
OUR SUPPLY CHAINS
Our supply chains include independent consultants and sub-contractors of professional services. We also procure consumables and other services locally where we operate.
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. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
The majority of our supply chain is considered to be low risk, given the nature of our services and any consultants used are likely to be professionally qualified and at low risk of Modern Slavery. However, some of our suppliers operate in industries where there is known to be a higher risk of modern slavery practices taking place. The following have been identified the following as the highest risk areas for us:
- IT Equipment
We engage with a number of international IT providers to source a range of IT equipment, including laptops, monitors and peripherals. The components of this equipment are often manufactured and assembled in countries where employment law protections and measures to prevent modern slavery practices are lacking in comparison to the UK.
Additionally, some of the raw materials used to manufacture these products are often sourced in areas where there is a high risk of child or forced labour, such as the mining of base metals.
- Office cleaning and maintenance services
We predominantly utilise external suppliers to provide our office cleaning and maintenance services at our premises, who in-turn often utilise employment businesses to supply labour for their operations. Given the high level of use of contingent labour and the junior level of many of the roles, there is a risk that suppliers could be targeted by traffickers or labour providers who do not adhere to appropriate standards.
- Courier and delivery services
Labour shortages in this industry make it susceptible to exploitative labour practices, such as forced labour including withheld wages, no or unfavourable work contracts, and/or excessive working hours.
Further steps in 2023
In 2023 we will be reviewing the risk of modern slavery with the larger suppliers of these higher risk items and intend to use due diligence processes to identify any modern slavery risks and seek assurances as to the safeguards and standards our suppliers (and their supply chain) have in place, including pay and working practices. This will initially focus on the areas that form the larger part of our supply chain.
TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
We regularly review ways to we can tackle slavery and human trafficking to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains.
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 31 December 2022.
Renny Borhan,
Chief Executive
HKA Global Limited
Date: 30 May 2023
