Modern Slavery Statement

A.  Context

Hanco Modern Slavery Statement 2024

At Hanco, we take seriously our responsibility to respect and promote human rights and to act with due diligence to avoid infringing on the human rights of others and address any impacts on human rights if they occur. We are committed to respecting human rights as set out in the Universal Declaration of Human Rights. Our Human Rights Policy (“Policy”) is also guided by the United Nations Guiding Principles on Business and Human Rights, the International Bill of Human Rights, and the principles set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.

We strive to foster safe, inclusive, and respectful workplaces wherever we do business and respect the fundamental rights of Hanco employees, which are: freedom from slavery and child labour; freedom to associate or not associate and collectively bargain; equal opportunity for everyone; a safe and healthy workplace; and freedom from discrimination and harassment. Where Hanco may impact the human rights of particularly vulnerable groups, such as migrant labourers, indigenous peoples, women, or children, we are also guided by other international standards that elaborate on their rights.

Introduction

This statement is published in accordance with the UK Modern Slavery Act. It outlines the approach we take to prevent modern slavery in our business and supply chains associated with the United Kingdom.

Hanco Global Solutions Ltd (“Hanco”, “Company,” “we” or “our”) published its first Modern Slavery statement in 2022. We continue to build our knowledge of the risks of modern slavery and the areas of our business that could face some of these challenges. We work across our business and supply chain to put the right practices in place to prevent and respond to any potential risks.

Modern slavery is unacceptable within our business and supply chains. We have a responsibility to respect the rights of people who work for the Company, and to do business with franchisees, Partners and business partners that respect human rights for their respective employees. We recognise there is no single solution to human rights issues, which is why it is critical that we engage with all of these stakeholders to build awareness and understanding.

Our business, structure and supply chains

We are proud to have run our business in the UK for over 25 years, having opened our first predecessor company, NovaSoft in 1997. We are a partnership operating in the UK, Romania, India, and the United States. Alongside the individual country business units, we have a head office function based in Milton Keynes, Buckinghamshire.

Our approach to modern slavery and ensuring human rights is underpinned by this same commitment. Our premier business partners and technology partners who supply Hanco with technology and contracted services (“Partners”) bring the spirit of entrepreneurship and commitment to communities; Partners are dedicated to highest levels of quality and safety; and Hanco Global Solutions Ltd facilitates learning and sharing across our global presence.

Hanco Global Solutions Ltd offers a powerful synergy across our main service areas, from IT and Infrastructure Management, to Cybersecurity and security-oriented web development.  Hanco Global Solutions Ltd, Hanco Global Europa SRL, Hanco Global Solutions Pvt Ltd, and Hanco Global Solutions, Inc. (together, “Hanco”) harnesses the power of our Partners and employees working together toward our purpose to make the online world safer for enterprises of all sizes.   

Our supply chains

Hanco has a straightforward global supply chain with Partners from the UK, USA, Europe, the Middle East and India.

Partners are a critical component of Hanco business. We build long-term relationships with our Partners and are proud that many of them have worked with us for decades. These long-term relationships enable us to have open and honest conversations and to share best practices.

We know that a large part of the success of the Hanco system lies in our trusted relationships with our Partners. We expect all Partners, regardless of the cultural, social, and economic context, to meet our expectations of fundamental rights for all people. This means treating their employees with fairness, respect, and dignity, and following practices that protect health and safety for the people working in their facilities.

Policies

Hanco supports the goals of the Modern Slavery Act and takes seriously its responsibility to act with due diligence to avoid infringing on the human rights of others and address any impact on human rights if they occur.

Employment practices

We conduct our activities in a manner that respects human rights as set out in the United Nations Declaration of Human Rights, and we are committed to ethical recruitment in our employment practices as a component of our overall human rights approach.

We prohibit direct or indirect fees or costs being charged to those seeking employment with or who are employed by the Company for the services directly related to recruitment for temporary or permanent job placement, unless legally permissible and within the legal limit. This includes where we may use private recruitment services or where we perform recruitment activities directly. Even where such fees or costs are legally permissible and within the legal limit, our policies and practices are designed to ensure that no one is indebted to the Company or to a recruiter in a manner that prohibits the individual from freely leaving their employment.

We do not retain an employee’s identity document such as passports or work permits, as a condition of employment for longer than 24 hours and only do so for legitimate administrative reasons, including for immigration checks. Hanco provides any agreements, whether oral or in writing, in a language understood by the person agreeing to be employed and expects that any recruiter, labour broker or employment agent will do the same and will be responsible for ensuring that the agreement is understood by the person agreeing to be employed.

Our global network of Hanco companies is comprised of separate legal entities, but we work hard to ensure that there are no modern slavery or human trafficking issues in their businesses. We provide our Hanco companies with guidance on recruitment practices and a People Review is carried out by either Hanco or the franchisee themselves as part of our Operations Performance And Customer Excellence (“PACE”). Operations PACE is a comprehensive assessment of our global companies to ensure guidance, including on modern slavery practices, is being followed as intended.

We may audit our Partners to ensure their employment practices are suitable and in line with our own employment standards. We do this with a particular focus on software engineer and developers and administrative staff at our various Partner locations. Our Hanco staff are told to report any concerning or suspicious behaviour that may suggest a third party is a potential victim of, or engaging in, modern slavery.

Human Rights

All Hanco policies are guided by the UN Guiding Principles on Business and Human Rights, the International Bill of Human Rights, and the principles set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work. Where Hanco may impact the human rights of particularly vulnerable groups, we are also guided by other international standards that elaborate on their rights. This Policy applies to Hanco Global Solutions Ltd and its majority-owned companies around the world. Hanco CEO is ultimately responsible for our corporate human rights efforts, while the Hanco partners also have oversight of human capital management matters affecting the Company.

A commitment to respect human rights is also set out in other Hanco policy documents, which apply to Hanco staff. We strive to foster safe, inclusive, and respectful workplaces wherever we do business and respect the fundamental rights of Hanco employees. Hanco staff are trained annually on the Standards of Business Conduct and are required to certify their understanding of and commitment to upholding the standards.

Employees may raise human rights issues, or report potential or actual human rights issues through a number of reporting channels, including contacting Human Resources or the Global Compliance Office. Reports received by the Global Compliance Office of alleged violations of the Standards of Business Conduct or other Hanco policies by Hanco employees are reviewed and addressed as appropriate.

We continue to work with external stakeholders to actively review our approach and global policies related to protecting human rights, to give greater transparency and clarity on our commitments and ensure they remain aligned with internationally recognised standards.

Assessing and Mitigating Risk in our Supply Chain

The Hanco Supplier Framework (“Framework”) applies to Hanco Partners globally. It sets out our expectations for Partners on critical topics including human rights, workplace environment, business integrity and environmental management. We expect supplier self-managed excellence in these four areas through the implementation of their own management systems.

Hanco provides a Supplier Workplace Standards and Guidance Document to assist Partners in meeting the standards. Hanco launched the first Supplier Framework in 2013 and has evolved and strengthened it over time to reflect updated international human rights standards, consultations with external experts, a human rights gap analysis, and dialogue with Partners.

Hanco expects all Partners to meet the standards, and ensure that their facilities meet the standards, and promote the principles outlined in the Framework. We also expect our Partners to hold their own supply chain, including subcontractors and third-party labour agencies, to the same standards contained in the Supplier Framework. Fundamental to the Framework is the expectation of ethical employment practices by Partners and their supply chain, including subcontractors and third-party labour agencies. The Framework prohibits any form of slave, forced, bonded, indentured or involuntary prison labour. Suppliers and third-party labour agencies are prohibited from retaining employees’ government-issued identification, passports or work permits as a condition of employment.

The Supplier Framework aims to help Partners understand Hanco expectations, verify compliance with our expectations and work toward continuous improvement.   Suppliers can also choose to undergo online training to understand the expectations of the Framework and other Hanco policies.

Hanco works with third-party auditing firms that have expert knowledge, local insight and an understanding of local languages and cultures. Auditors also conduct private worker interviews and review facility records and business practices to assess compliance with the Framework.

Modern slavery risks are addressed specifically as part of the audit, including a review of ethical recruitment practices to verify that workers are employed under voluntary conditions and have freedom of movement. This includes verification that workers are not charged illegal fees as a condition of employment; worker contracts are in local language and signed by the worker; and that Partners do not retain workers’ government-issued identification, passports or work permits.

Understanding and managing risk

An important element of the global human rights due diligence approach is understanding global and national human rights risks and using this information to support the Supplier Workplace Accountability programme. In addition to the audits described above, Hanco assesses the potential human rights risks of our supply chains, including modern slavery risks, supply chain mapping, and Hanco Partner and stakeholder engagement.

By identifying the most salient human rights issues within these supply chains, we aim to strengthen our risk management procedures, develop appropriate improvement plans, and increase awareness of these issues within our business.

Effective action

Where non-compliance is identified, Partners work with a third-party audit firm to complete a corrective and preventative action plan to address the non-compliance. The plan must provide specific time frames within which corrective action will be taken, root causes analysed, and policies and procedures updated. In addition, the plan must be designed to avoid recurrence of the non-compliance and establish specific accountability. In instances of significant non-compliance, Partners are subject to a follow-up audit to ensure that the non-compliances have been properly addressed.

In addition to training, auditing, and other aspects of Hanco’s Supplier Framework, Hanco requires that Partners implement their own internal reporting mechanisms to ensure their employees have a confidential, safe, and timely way to report workplace concerns without the fear of retaliation.

The Framework stipulates that Partners must create internal grievance mechanisms and programmes for handling reports of workplace grievances, including anonymous reports. In addition, Hanco HQ and an email address are open to third parties, including Partners and their employees, to raise concerns with breaches of the Framework.

Training on modern slavery and human rights

To help employees understand human rights, we will be making training for staff on the Human Rights Policy available in 2024. The training is planned to have a section on forced labour that identifies particularly vulnerable groups and outlines Hanco commitments surrounding ethical recruitment. Hanco employees are also trained regularly on the Standards of Business Conduct and are required to annually certify their understanding of and commitment to upholding the Standards. Hanco Global Solutions Ltd.’s senior partners and leadership have also received in-person training in partnership with an external human rights consultancy.

Given their important role in working with Partners, Hanco technology and client services procurement employees undergo in-person and webinar trainings on supporting Partners in meeting their expectations under the Supplier Framework.

Additionally, Hanco Supplier Framework is shared with all Partners and provides detailed guidance on each aspect of the Framework and how Partners and their supply chains can meet our expectations. Hanco reinforces the all Partners should:

• ensure their hiring process, and that of their recruitment agencies, provide people employment under voluntary terms;
• maintain legally accepted age verification records to demonstrate all workers are of legal working age when they started work;
• respect employees’ rights to associate, or not, with any group of their choice, as permitted by law, without fear of reprisal, intimidation, or harassment; and
• respect the rights of people to bargain collectively where such rights are established by law or contract.

Hanco also offers optional live training sessions for Partners with external human rights and supply chain experts. 

Partnering to improve standards and identify emerging issues

Hanco is committed to engaging with stakeholders to continue to advance our approach to human rights.

Hanco Global Solutions Ltd engages with stakeholders in our system in a variety of ways. For example, within our Company, Hanco employees provide feedback through multiple reporting mechanisms, including via people managers, human resources and through participation in surveys. Within our supply chain, external monitoring firms conduct on-site audits of supplier facilities through the Supplier Framework.

Looking forward

We know that there is no single solution to the challenges of modern slavery and human trafficking, and we must therefore continue to learn and understand the associated risks and warning signs. By working across all elements of our business and supply chain, we can continue to build our knowledge of these issues and take steps to improve our collective awareness. We will engage these different elements of our organisation, as well as expert third parties, to identify areas for improvement.

Statement approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st December 2022.  The Partners of Hanco Global Solutions Ltd approved this statement on 26th January 2023.

 

Neil Westerby

Chief Executive Officer, Hanco

 

1. Supporting Material

 

Process documents, examples, templates, external materials etc.

This Policy should be read in conjunction with the following Hanco policies which are available on the Intranet: ·         Corporate and Social Responsibility Policy ·         Sustainable Procurement Policy ·         Hanco Supplier Framework

1. Contact Points for Queries or Guidance:

 

Name	Contact Details
Neil Westerby, Hanco CEO	ne**@ha*********.com

Review and Approval

 

Sign Off
Neil Westerby	26 January 2024
Hanco Global Solutions Ltd	26 January 2024
Next Review Date
This policy should be reviewed at least annually or when significant change occurs to the policy subject matter. The next review date for this policy is October 2025.