Modern Slavery Policy
PURPOSE
The purpose of this policy is to ensure that the Company (Hawkins) operates in compliance with the Modern Slavery Act 2015 and other relevant international legislation, promoting ethical practice and respect for human rights globally.
INTRODUCTION
The Company has a reputation for conducting its activities in a responsible manner. It is one of the key factors essential for the continued success of the Company that the impartial and ethical principles existing within the organisation and the relevant government regulations are always adhered to.
The Company prohibits the solicitation and facilitation of any type of slavery and human trafficking by its employees, or agents (partners or suppliers) to or from any external organisations or individuals. The Company is fully committed to preventing modern slavery and human trafficking in all its operations and supply chains and will report any violation of this policy. The Company will not support or deal with any business knowingly involved in slavery or human trafficking.
risks
The key risks are as follows:
1. Customer activities – we undertake a review of all new clients to ensure we understand their identity, ownership and ethical standing.
2. Outsourced activities – we assess our suppliers to ensure that we have a mutually trustworthy relationship and that they can comply with all regulatory and statutory requirements.
The risk of slavery within Hawkins’ operations is very low. However, to minimise the existing risks we thoroughly check that all of Hawkins’ employees have the right to work in the country of appointment and are paid at or above the (local) national minimum wage. The same diligence is applied to our subcontractors and suppliers to ensure that any (agency or hired) staff are similarly checked by their respective employer and that no bonded labour is used for Hawkins’ business.
To reduce the risk relating to this policy the Company will:
- Communicate this policy to all its staff;
- Provide training to all staff on the risks of modern slavery and how to identify them;
- Encourage staff to report all potential acts of violation of this policy;
- Take seriously any investigation related to violation of this policy;
- Implement supplier due diligence processes;
- Take decisive action against any employee, supplier, interested party or client found to have breached this policy.
responsibilities and reporting
It is the responsibility of all staff to maintain the integrity and ethical behaviour of the Company. If there is any doubt as to the nature of an activity, which comes to the attention of Hawkins’ staff, then the activity should be reported to the HR Director who will review the matter with members of the Board and take the necessary action. In the absence of the HR Director other Board members should be approached to report any such violation.
This Policy is regularly reviewed and may change from time to time. The Policy was last updated on 15th May 2025 and is Version 4.0.