This statement is made pursuant to the Modern Slavery Act 2015 (the “Act”). The Act requires companies to explain on an annual basis the steps taken to prevent acts of modern slavery and human trafficking occurring in their business and supply chains. This statement sets out ABI’s actions to understand all potential modern slavery and human trafficking risks in relation to its business and to put in place steps aimed at ensuring that there is no slavery or human trafficking in its business and supply chains. ABI recognises that it has a responsibility to take a robust approach to slavery and human trafficking. ABI is absolutely committed to preventing slavery and human trafficking in its corporate activities and to ensuring
its supply chain is free from slavery and human trafficking.
2. OUR STRUCTURE AND BUSINESS
ABI is a manufacturer of hand-crafted caravan holiday homes and luxury lodges which distributes its products through dealers and direct to holiday parks mainly in the UK but also to other European countries. We have a well-established supply chain for components, being mainly from UK suppliers. Certain products are sourced from European suppliers. All new suppliers are subject to appropriate due diligence before we commence trading with them. The ABI Group is headed by Hgate Holdings Limited which is registered in England & Wales. Its principal operating subsidiary is ABI (UK) Limited which is registered in England & Wales.
3. OUR POLICIES ON MODERN 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 our supply chains. Responsibility for enforcing our Anti-slavery policy rests ultimately with the Board of Directors who manage this responsibility in the following ways:
- ABI has an Anti-Slavery and Anti Human Trafficking Policy. All staff in positions of responsibility which might carry a risk of contact with
Modern Slavery and Human Trafficking are briefed on this policy.
- We operate a whistle blowing policy and encourage our 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. ABI’S whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
- Our recruitment practices mean that we use specified, reputable
employment agencies to source labour (where appropriate) and we vet the practices of any new agency before accepting workers from that agency. We check prospective employees eligibility to work in the UK as a safeguard against breaches of the Act.
- We carry out risk assessments to assess areas of risk relating to
Modern Slavery and Human Trafficking within our business and supply chain. We do not consider that there are currently any areas which are susceptible to higher risk. This risk assessment includes a supplier questionnaire.
- Where appropriate we provide training to our employees in relation to Modern Slavery and Human Trafficking.
4. OUR DUE DILIGENCE PROCESS
As part of our initiative to identify and mitigate risk we have conducted a risk assessment to identify any practices which would constitute slavery or human trafficking within ABI and our supply chain. We have formally engaged with suppliers and asked them to complete a questionnaire to confirm their position on modern slavery and to identify any risk of modern slavery and human trafficking. We remain committed to working with our suppliers to ensure business is conducted ethically and honestly. Should a supplier fail to provide us with adequate assurance that their business and supply chain is free from slavery and human trafficking we would suggest corrective action but in the event that this corrective action is not promptly implemented we would consider our future with the supplier. We may also report any such supplier to the relevant authorities as appropriate.
As a matter of course to provide an ongoing assessment we:
- Visit our key suppliers regularly and require completion of supplier
- We assess whether prices quoted are unrealistic or questionable.
- We review our standard terms and conditions from time to time to
ensure they document our expectations in relation to a suppliers
adherence to the Modern Slavery Act.
5. EFFECTIVENESS OF OUR APPROACH
We have made good progress in increasing the levels of understanding of Modern Slavery and Human Trafficking in our business. We have not identified any areas of higher risk, however we recognise the importance of ongoing monitoring both within our business and supply chain to mitigate risk to the fullest extent possible.
6. APROVAL OF THIS STATEMENT
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and has been approved by the Board of Hgate Holdings Limited in relation to the financial year ended 31st August 2021.