Modern Slavery Statement
Introduction from the Board of HAE Global Limited
We are committed to improving our practices to combat slavery and human trafficking. We are also committed to
ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout
our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect
the same high standards from all of our contractors, suppliers and other business partners, and as part of
our contracting processes, we include specific prohibitions against the use of forced, compulsory or
trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that
our suppliers will hold their own suppliers to the same high standards.
Organisation's structure
We are a provider of logistic services in the aviation sector. We are a part of the HAE Group (HAE Group),
and our ultimate parent company is HAE Global Limited. HAE Global Limited has its head office in the United
Kingdom. We have over 250 employees worldwide and operate in the USA, Africa, Europe and the Middle East
regions.
Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in
any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with
integrity in all our business relationships and to implementing and enforcing effective systems and controls
to ensure slavery and human trafficking is not taking place anywhere in out supply chains.
Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk we carry out certain preliminary enquiries to ensure
that there is no risk to our businesses being associated with, or party to, any form of promotion or
facilitation of slavery or human trafficking.
We have in place systems to:
- Identify and assess potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
- Protect whistle blowers and promote disclosure.
Supplier adherence to our values
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and
contractors comply with our ethics we have in place a rigorous supply chain compliance programme.
We have a dedicated compliance team, which consists of representatives from the following departments:
- Legal
- Audit and compliance.
- Human resources.
- Sales.
Risk and Compliance
HAE Group has evaluated the nature and extent of its exposure to the risk of modern slavery occurring in its
supply chain through its Legal Team. As our core business is focused on the provision of aviation freight
logistic services, and working with experienced and bespoke solution driven entities including airlines and
freight forwarders (rather than in relation to agriculture, retail or manufacturing, which are sectors we
perceive to present a higher risk of labour exploitation and modern slavery), we do not consider that we
operate in a particularly high risk sector. This evaluation process will continue on an annual basis.
Training
Given our view that the Group’s exposure to modern slavery risk is limited, and the existing due diligence
processes we already have in place as an organisation, except as noted above, we have not implemented any
specific training of our UK employees or key performance indicators in relation to modern slavery and human
trafficking during the previous financial year.
Our effectiveness in combating slavery and human trafficking
Following a review of the effectiveness of the steps taken in the previous financial year to prevent modern
slavery or human trafficking occurring in our business, we intend to take the following further steps to
combat slavery and human trafficking during the course of the 2018 financial year:
- continue to monitor the risk to our supply chain on an ongoing basis;
- implement specific training of all UK based employees to ensure a high level of understanding of the
risks of modern slavery and so they are aware of what to look out for in respect of modern slavery; and
- consider further how best to map the supply chains of our overseas businesses.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's
slavery and human trafficking statement for the financial year ending 31 December 2019.
Neville Karai
HAE Global Limited