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Slavery and Human Trafficking Policy


Harwin takes a robust approach to slavery and human trafficking both within our own organisation and that of our supply chain.

This statement sets out how we aim to understand the potential modern slavery risks and the steps we will take to minimise such risks, despite at present not being required to publish a legal disclosure under UK legislation (The UK Modern Slavery Act 2015).

We have introduced a basic code of conduct to enhance our existing policies and procedures relating to recruitment, the employment lifecycle and the supply chain qualification process including its subsequent management.

All members of staff, suppliers, contractors and associates are made aware of our approach to dealing with the risks of slavery and human trafficking and their involvement in its prevention.


Code of Conduct

Employees – Harwin makes it clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

Suppliers – Our suppliers must demonstrate the highest standards of ethics and where necessary prove that they provide safe working conditions, treat their workers with dignity and respect and act ethically and within the law in their use of human resources.

Recruitment agencies – The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Whistleblowing – The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.


This Policy is also available in PDF format for download.

Form HF-299; Issue 2; Date 18-Oct-2019; C/Note 22134

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