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:

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:

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:

  1. continue to monitor the risk to our supply chain on an ongoing basis;
  2. 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
  3. 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.

Colin White
HAE Global Limited