Hanwha Techwin Europe Ltd.
Modern Slavery Act Statement
Financial Year 2021
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 2022.
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 2021, 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 2023 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.
Section 172(1) Statement
Companies (Miscellaneous Reporting) Regulations 2018
The Companies (Miscellaneous Reporting) Regulations 2018 applies to accounting periods beginning on or after 1 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.
(A) 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.
(B) 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.
(C) 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.
(C) The need to foster the company’s business relationships with suppliers, customers and others (Continued)
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.
(D) 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. Hanwha Corporation have also set up a Solar Forest project to plant trees on deforested land. To promote more environmental sustainability, Hanwha has pledged to plant a tree in 2021 for each employee that sends a photograph showing they have made a change in behaviour such as using reusable coffee cups, turning off light etc. 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 their company fleet to hybrid cars.
(E) The desirability of the company maintaining a reputation for high standards of business standards of 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.
(F) The need to act fairly as between 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:
(i) 2021 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.
All managers 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 2021 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.
(ii) Closure of B2C business – The decision was taken during 2021 to end the company’s B2C business. There is fierce competition in the consumer security product market with only low margins being achievable. The company decided to concentrate all its efforts on the development of innovative B2B products including A.I. technology, which would have the potential to achieve more profitable returns. The company’s final stock of B2C products will be sold in 2022, to fulfil an existing contract. Following this the company’s B2C business will end. Before taking the decision the directors considered the impact that it would have on the company’s stakeholders.
The company’s B2C product offering had already been reduced over the past year or so, and as a result so had the customer base. The decision to stop selling B2C products altogether was not expected to have any significant impact on the remaining customers.
The effect of the decision to close the B2C business would have on the existing employees was also considered. In 2021 the company employed 2 members of staff in connection with its B2C business. It was decided that the skills of both employees could be utilised by the B2B side of business. They were therefore both offered alternative positions within the company.
The directors concluded that their decision to close the B2C business would help focus resources on the more profitable B2B sector of the security industry without causing any significant negative
impact on its stakeholders.