Hispec Modern Slavery Policy

Introduction

Hispec Electric Products Limited is committed to preventing modern slavery and human trafficking in all its business activities and supply chains. This policy outlines our approach to ensuring that modern slavery does not occur within our organization or our supply chains.

Our Commitment

We are dedicated to conducting our business with high ethical standards and integrity. We do not tolerate any form of modern slavery, including forced labour, child labour, and human trafficking. Our commitment is aligned with the principles set out in our Code of Conduct (the Code), Supplier Code of Conduct, and associated Human Rights policy.

Scope

This policy applies to all employees, contractors, suppliers, and business partners of Hispec Electric Products Limited.

Responsibilities

• Management: Ensure compliance with this policy and provide training to employees.
• Employees: Report any concerns related to modern slavery and adhere to the policy.
• Suppliers: Comply with our ethical sourcing requirements and ensure their supply chains are free from modern slavery.

Due Diligence

• Supplier audits and assessments.
• Requiring suppliers to complete self-assessment questionnaires.
• Engaging with suppliers to improve their practices where necessary.

Training and Awareness

We provide training to our employees to help them understand and identify signs of modern slavery. We also raise awareness among our suppliers about our commitment to preventing modern slavery.

Reporting and Whistleblowing

We encourage employees and suppliers to report any concerns related to modern slavery. Reports can be made confidentially through our whistleblowing channels.

Continuous Improvement

We are committed to continuously improving our practices to combat modern slavery. We regularly review and update our policies and procedures to ensure their effectiveness.

Human Rights Principles

• We are committed to protecting and preserving the rights of our employees, those employed in our supply chain, and those affected by our operations.
• We are committed to acting in a socially responsible manner, complying with applicable laws, and respecting the communities where we operate.
• We believe that all employment should be freely chosen and commit to refrain from any form of forced or involuntary labour or human trafficking.
• We are opposed to the use of any form of child labour or practices that inhibit the development of children.
• We are alert to the risks vulnerable people may face and seek to ensure that this group is free from discrimination and exploitation.
• We will only work with suppliers whose core values and commitment to ethical business conduct match our own and require that their conduct always meets our standards, including signing up to our Supplier Code.

Employee and Supplier Expectations

All employees are required to adhere to our Code and Company policies, in addition to any specific local requirements. Our employee performance management processes include an assessment of how individuals embody our company values, behaviours, and ethical conduct.

We extend our sustainability expectations and ethical principles to our suppliers and partners through our Supplier Code of Conduct.

To do business together, we expect all suppliers to be ethical, responsible, and to fully comply with all applicable laws and regulations. Our Supplier Code of Conduct sets out the behaviours, practices, and standards we expect our suppliers to demonstrate and comply with, all of which are based on our own Code, policies, and standards. Selected suppliers are contractually required to adhere to this or a mutually agreed alternative.

Identifying, Assessing, and Mitigating Modern Slavery in Our Supply Chain

• Child Labour: Suppliers must not employ anyone under the age of 15 years or, where it is higher, according to the applicable law, the mandatory national school leaving age.
• Modern Slavery & Forced Labour: Suppliers must never use or support practices that inhibit the development of children in accordance with applicable ILO conventions. We believe that all employment should be freely chosen.

In addition, our Supplier Code of Conduct contains requirements related to the responsible procurement of raw materials, an area we recognize as being at higher exposure to human rights risk. This requests suppliers to provide us with products and materials, including constituent minerals, that are sourced responsibly and verified as ‘conflict free’ in accordance with OECD guidelines.

Adherence with our Supplier Code of Conduct is mandated for selected suppliers through our General Conditions of Purchase and precedent contractual terms. This is in addition to all applicable laws and regulations in the country or countries where our suppliers operate. In the event that our Supplier Code of Conduct sets out a higher requirement than local regulation, suppliers are expected to adhere to that higher requirement. Our Supplier Code of Conduct requires our direct suppliers to disseminate these requirements throughout their own supply chain.

If a supplier’s practices are found unsatisfactory or non-conformant to our Supplier Code of Conduct, the issue is investigated and escalated appropriately. We address these issues on a case-by-case basis, seeking advice from subject matter experts and legal counsel where appropriate. In the event of significant non-conformance, we retain the right to terminate any contractual agreement with immediate effect.

We perform regular risk analysis to identify, prevent, mitigate, and if required, remediate human rights risks, including modern slavery risk in our supply chain. In the event that a risk or violation is identified in our own operations or supply chain, the risk or violation is weighted and prioritized, and appropriate steps taken to mitigate the risk or address the violation.

In the past, there have been no instances of modern slavery linked to Hispec Electric Products Limited’s products or services in our supply chain. In the event that an instance of modern slavery is identified, and corrective or remedial measures are required, we will work with our suppliers to consider their appropriateness in light of the best interests and protection of these individuals or groups.

Training and Communication

All employees receive regular communications on ethical behaviours. We also deliver an annual company -wide mandatory learning program centred on our values and behaviours and our safety, security, and legal obligations.

We track completion of this training as part of our all-employee performance metrics. We support awareness training with groups that have direct oversight into human rights-related concerns, for example, mental health training for leaders.

Speak Up Culture

We strive to create an environment where everyone feels valued and actively encouraged to speak up about questions or concerns without fear of negative consequences. This is a vital part of enhancing our culture of inclusion and belonging.

During 2023, no concerns were raised related to modern slavery, forced labour, child labour, or human trafficking. In the event that any future investigation identifies confirmed or potential victims of modern slavery, we will work in the best interests and protection of these individuals or groups and apply remediation which mitigates the impact on the most vulnerable people.

Review

This policy will be reviewed annually and updated as necessary to reflect changes in legislation and best practices.

Approval

This policy has been approved by the Board of Directors of HiSpec Electric Products Limited.