Modern Slavery Act Statement
Apollo Fire Detectors Limited is a Halma company, and is committed to respecting human rights and preventing modern slavery, in accordance with the following Halma Modern Slavery Act Statement.
Halma plc (Halma) supports the provisions set out in the Modern Slavery Act 2015 (Act) and has taken steps to prevent modern slavery occurring in its supply chain and within its own operations. This statement has been published in accordance with Section 54 of the Act and applies to Halma and its subsidiaries (the Group) in respect of the financial year ended 31 March 2021. The individual companies which meet, or have met in the past, the requirement to report under the Act have been specifically mentioned below.
Halma has worked in partnership with STOP THE TRAFFIK, a UK-based charity which works to disrupt and prevent human trafficking by raising awareness, informing and equipping individuals, organisations and communities to take action to combat this global crime. STOP THE TRAFFIK conducted a modern slavery risk mapping exercise on our supply chain, the results of which have been used to identify and mitigate key areas of risk.
Business Structure and Supply Chains
Halma employs over 7,200 people in 42 businesses operating in more than 20 countries. Each business is a separate legal entity and has its own board of directors with accountability for implementing controls set by Halma’s group legal and compliance framework.
Our purpose - to grow a safer, cleaner, healthier future for everyone, every day - drives our strategy and culture. Our companies and products have a core focus on safety, health and environmental markets.
Figure 1: Distribution of Halma’s production and office facilities as at 31 March 2021
Our 42 businesses are grouped within three sectors:
1. Safety – 16 Businesses
Technologies that save lives, protect infrastructure and enable safe movement, and also technologies that protect people and assets at work across a range of critical industrial and logistics operations.
2. Environmental & Analysis – 12 Businesses
Technologies that monitor and protect the environment and ensure the quality and availability of life-critical resources.
3. Medical – 14 Businesses
Technologies that enhance the quality of life for patients and improve the quality of care delivered by healthcare providers.
You can find out more about our companies and what they do in the Our Companies section.
The location of our companies and corporate offices can be found in our Group directory.
Halma is the parent company of the Group and the Group Executive Board set the framework under which our businesses operate. We have an autonomous organisational structure with each Halma company operating as a separate legal entity with its own board of directors with clear lines of accountability. As the directors and officers of their companies, local management are empowered to lead their business and are responsible for their own supply chains. All businesses are required to complete a semi-annual internal control certificate which confirms that they have complied with key areas of control and compliance mandated by Group’s policies and procedures (see Policies and Procedure below for more information). This certificate includes a specific provision confirming that all employees have read and signed our Code of Conduct which communicates our approach to critical human rights, business conduct and ethical matters, including modern slavery.
8 Halma companies have either met, or met in the past, the reporting criteria under the Act:
- Apollo Fire Detectors Limited (Apollo)
Designs and manufactures fire detectors for commercial and industrial applications.
- Bureau d'Electronique Appliquée S.A. (BEA)
Designs and manufactures motion, presence and safety sensors.
- CenTrak, Inc. (CenTrak)
Designs and manufactures real-time location services for healthcare facilities.
- Crowcon Detection Instruments Limited (Crowcon)
Designs and manufactures gas detection instruments.
- HWM-Water Ltd (HWM)
Designs and manufactures monitoring and telemetry equipment for water, wastewater and gas networks.
- Medicel AG (Medicel)
Designs and manufactures specialist eye surgery instruments.
- Microsurgical Technology (MST)
Designs and manufacturers surgical devices and instruments used to improve sight.
- Texecom Limited (Texecom)
Designs and manufactures electronic intruder alarm systems.
Policies and Procedures
Halma has a culture of openness, integrity and accountability. We require our employees to act fairly in their dealings with fellow employees, customers, suppliers and business partners. We are committed to preventing modern slavery and human trafficking in our operations and in our supply chains. The Group has a range of policies and procedures which mitigate the risk of modern slavery.
1. Modern Slavery Act Policy
Halma has a Modern Slavery Act policy in place which applies to all businesses within the Group. This policy is important as it encourages a consistent approach to modern slavery prevention across our de-centralised company structure.
The policy outlines:
• What modern slavery is, which industries are at heightened vulnerability, which countries and sectors are known to be high-risk, and which indicators should raise concerns.
• The requirements of the Act.
• Recommendations for best practice mitigation and methods for determining their operations and supply chain modern slavery risk.
All businesses are required to review and consider the areas set out within the policy.
2. Code of Conduct
Our worldwide Code of Conduct (Code) sets out the ethical standards that govern the activities of the Group, our employees, and business partners. The Code includes a specific provision concerning the prevention of modern slavery and human trafficking, setting out:
• Our clear commitment to never tolerate, or engage with those who do tolerate modern slavery, human trafficking, and other abuses of labour rights.
• An explanation of how modern slavery prevention falls within the remit of our Human Rights and Labour Conditions Policy.
The Code is available on our website and has been translated into nine languages.
It is a Group-wide requirement that all our employees receive, and sign to acknowledge that they have read, the Code.
3. Human Rights and Labour Conditions Policy
Modern slavery prevention falls within Halma’s human rights approach to sustainability. Halma’s Human Rights and Labour Conditions policy endorses the dignity and rights of all individuals as established in the Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work. The policy commits Halma to integrate compliance with human rights throughout the Group’s activities, ensuring that human rights are respected at all times and are protected within the Halma’s sphere of our influence.
The Policy includes several commitments which are key for modern slavery prevention:
• To never tolerate forced or bonded labour, and to never require employees to leave deposits or identity documents with their employer.
• To never tolerate child labour and to require all employees to be above the minimum legal working age.
• To respect any employee’s right to form or join a trade union, and to never discriminate against members of trade unions.
• To ensure that employees always have the freedom to leave their employer.
Our Human Rights and Labour Conditions Policy can be found here.
4. Whistleblowing Policy
The Group has a whistleblowing policy and an established third-party whistleblowing service, accessible both online and by telephone, which allows employees in any of our businesses to raise concerns in confidence, anonymously (where permitted by law) and independent of their company. Our third-party whistleblowing facility is not limited to employees and can be used by anyone, including our customers and suppliers.
In order to ensure that the mechanism remains accessible and trusted by our employees, the whistleblowing policy explains how the process works, how anonymity will be preserved, and an assurance that a whistleblower will not be treated negatively for raising an issue in good faith.
Halma’s Board (and Audit Committee where concerns relate to potential financial misconduct or fraud) reviews the nature of reports made through the whistleblowing channel in order to ensure that it remains an effective mechanism for raising concerns, that such reports are properly investigated under the direction of the Company Secretary and that there are no recurring trends that would suggest underlying cultural or ethical issues in the Group.
Any suspected or confirmed cases of modern slavery or human trafficking should be reported through the whistleblowing service. No suspected or confirmed cases of modern slavery have been reported to date.
Our Whistleblowing Policy can be found within our Code.
5. Sale and Distribution Terms and Conditions
During 2018/19, our UK businesses updated their standard sale and distribution terms and conditions. These terms specifically include a clause on compliance with anti-slavery laws and require distributors to not engage in any modern slavery practice. During 2019/20 we created standard sale terms requiring anti-slavery compliance.
In 2019/20 Halma worked with STOP THE TRAFFIK to conduct a modern slavery risk map of our global supply chain.
STOP THE TRAFFIK’s inherent risk mapping methodology consists of ranking each supplier on a scale of 1 to 5 based on their economic sector and country of operation, where 1 is the lowest risk of modern slavery and 5 is the highest. These rankings combine intelligence from multiple open-source datasets with analysis from STOP THE TRAFFIK’s human trafficking Research and Intelligence Team. The inherent risk mapping is a theoretical modern slavery ranking which identifies where risks are most likely to be within our supply chain - it does not confirm their existence.
The risk-mapping project identified that our highest risk suppliers broadly fell into two risk areas:
1. Manufacturers in China producing electrical and metal components for our products.
2. Suppliers operating across Europe and North America in high-risk sectors, providing our company with services such as logistics, warehousing, labour provision, and construction.
Throughout 2020/21 we have continued to provide support and advice to our companies to enable them to conduct effective due diligence and mitigate their inherent supply chain risk.
Our supplier due diligence activities are conducted at the individual company level.
Below is a summary of the steps taken to prevent modern slavery by those companies that meet, or have met in the past, the Modern Slavery Act threshold. Due to the on-going COVID-19 pandemic, certain companies have faced challenges around conducting on-site audits in the usual manner and have therefore had to adapt their processes accordingly.
Apollo’s commitment to respecting human rights and preventing modern slavery is outlined in its supplier handbook which is sent to all suppliers. This handbook clearly states that all Apollo suppliers are required to comply with modern slavery laws and respect human rights, and that failure to do so could void supplier agreements.
All suppliers are assessed annually for a variety of risk variables, including modern slavery prevention. Risk factors such as suppliers’ country of operations, membership to the Responsible Business Alliance, and company Modern Slavery Statements are all assessed. When a supplier is perceived to be high-risk for modern slavery, full on-site audits are carried out. In light of the restrictions due to the pandemic, it has been difficult to carry out on-site assessments of suppliers. Apollo has developed a virtual approach for auditing, using video and documentation evidence as part of a ‘live’ session. In addition, the Apollo board and relevant employees have undertaken Halma’s Modern Slavery Act compliance training.
All of BEA’s suppliers are audited before starting any new business. A specific question on compliance with the Modern Slavery Act is a key trigger before new business can commence with BEA.
For incumbent suppliers, BEA Quality and Purchasing teams visit and audit each supplier regularly (this can be as frequent as every four months or on a cycle of every two years, depending on vendor turnover with BEA). These audits review working conditions, the working environment, worker safety and labour conditions.
BEA do not have any business with any vendors that operate in high risk countries. The COVID-19 pandemic has however reduced the opportunity to travel and carry out supplier on-site visits during this time.
BEA recently reviewed its purchasing terms and conditions to ensure that they met best practice and now include a specific requirement on all suppliers to adhere to the UK Modern Slavery Act. These purchasing terms and conditions can be viewed on the BEA website and are available in English, French and Chinese.
The BEA board and relevant employees have undertaken Halma’s Modern Slavery Act compliance training.
As a part of recent new supplier due diligence and on-boarding, all new suppliers are required to complete a supplier questionnaire related to modern slavery and human trafficking. The questionnaire establishes each supplier’s operations and supply chain risk. It includes questions which review: the policies and procedures the suppliers have introduced to mitigate their modern slavery risk; how they manage their own supply chain risk; and what awareness training the supplier has conducted. The CenTrak board and relevant employees have undertaken Halma’s Modern Slavery Act compliance training.
Crowcon conducts a preliminary modern slavery risk assessment on all its suppliers. This risk assessment is based upon geography, the commodity being purchased and the nature of the transaction.
During 2020/21, the restrictions due to the pandemic imposed obvious issues with the Supplier Quality Manager being able to perform its usual onsite quality assessments to suppliers that are located in high-risk countries, according to the Global Slavery Index. However, Crowcon has continued to send supplier quality audit questionnaires to its suppliers which includes the Modern Slavery section and code of conduct.
Crowcon has recently updated its Supplier Quality Questionnaire to include questions regarding its suppliers’ modern slavery risk, so that the tier two supply chain can be assessed for high-risk activities. Crowcon refreshes the quality audits and agreements with its suppliers on an on-going basis. The Crowcon board and relevant employees have undertaken Halma’s Modern Slavery Act compliance training.
HWM is committed to respecting human rights and preventing modern slavery. All senior management and those involved in supply chain have undertaken Halma’s Modern Slavery Act compliance training. New employees sign the Halma Code of Conduct, confirming their understanding and commitment to the policy. The supply chain has been reviewed to identify potential risk areas. New suppliers are required to complete a questionnaire supporting their adherence to the Modern Slavery Act and existing suppliers are subject to ongoing monitoring.
Medicel’s supplier quality agreement includes a provision that requires suppliers to comply with the Modern Slavery Act. In addition, Medicel uses a Supplier Labour Standard Assurance Questionnaire that requires suppliers to provide due diligence information such as the number of migrants they employ, if there is a workers’ representative and a summary of the steps that have been taken to mitigate risk, such as labour standards policies and informing staff of their rights. Every new or existing supplier based in a country with a perceived high prevalence of modern slavery is being audited. The Medicel board and relevant employees have undertaken Halma’s Modern Slavery Act compliance training.
MST has complied with Halma’s Modern Slavery Act policy and incorporates appropriate provisions into Terms and Conditions for all purchase orders. MST has performed a risk assessment using data from NGOs to identify high-risk suppliers in locations where prevalence is high and government oversight is low. MST’s highest risk suppliers, located in India, now have in-country monitoring and receive in-person audits annually.
All MST board members have undertaken the Halma-sponsored Modern Slavery Act training.
Texecom is committed to respecting human rights and preventing modern slavery and continues to comply with Halma’s Modern Slavery Act Policy. Members of the board and senior leadership team have undertaken Halma’s Modern Slavery Act compliance training and this continues to be rolled out throughout the full employee base within Texecom to increase compliance and understanding at all levels.
Texecom have a renewed focus on rolling out supplier monitoring and compliance requirements for 2021, to further reduce all remaining risk factors with the critical target for 2021 being the completion of the supplier handbook (which defines the consequences to suppliers of non-compliance with the Modern Slavery Act). Substantial progress has been made in supplier reporting and vetting, with Modern Slavery Act vetting completed for new suppliers and the ongoing reporting progressed with existing suppliers.
Halma runs an online modern slavery awareness training in partnership with VinciWorks. Senior management, subsidiary board directors and other relevant employees are automatically enrolled on this course. To date, over 3,800 employees have successfully completed this online compliance training, an increase of 1,000 since our last statement. The training covers:
• What modern slavery is and which groups are at heightened vulnerability.
• How modern slavery affects UK companies and the legal implications.
• How to identify high-risk suppliers and operations.
• How to identify cases of modern slavery and report concerns.
As Group Chief Executive, I will continue to lead this important agenda for Halma and our Group and will report annually on the steps that we have taken and will be taking to prevent modern slavery.
A copy of this Statement is available on the Company’s website at www.halma.com and also at the Modern Slavery Statement Registry.
This statement was approved by the Board of Halma and signed on its behalf by:
Group Chief Executive
22 July 2021