Modern Slavery Act Transparency Statement

In this document the following abbreviations and definitions shall have the meanings set out below:
 

Our purpose is to ‘Build a Future We Can All Trust’ which includes ethical considerations and trust in each other. Thales considers that modern slavery is an abhorrent crime that inflicts immeasurable harm on vulnerable adults and children in the UK and across the world. Thales fully supports the principles of the UK Modern Slavery Act of 2015 (MSA) and is firmly committed to effectively tackling potential risks of modern slavery associated with our operations or supply chain.

This Modern Slavery (MS) statement is made on behalf of the parent company Thales UK Limited and all Thales UK wholly-owned operational companies in the UK which meet the MSA threshold, as listed below. All such companies operate as a single integrated organisation within the UK, subject to the same policies and management systems:

Thales UK Limited
Ground Transportation Systems UK Limited (formerly known as Thales Ground Transportation Systems Limited) 
GTS Quadrant Limited (formerly known as Thales GTS UK Limited)
Thales DIS UK Limited 
Thales DIS CPL UK Limited

Thales Alenia Space UK Ltd is also included in this MS statement as it is a majority owned joint venture subsidiary of Thales Group and registered in the UK.

Separate MS statements are also published by our joint venture partners, where Thales UK has a shareholding of 50% or less. These companies include AirTanker and Aquila Air Traffic Management Services.

Headquartered in Paris, Thales is a global technology leader in Aerospace, Defence and Security, Digital Identity and Security, Space and Transport generating revenues of €17.6 billion for the year ending 31st December 2022, with more than 77,000 employees on five continents and 20,000 suppliers worldwide. 

Thales’ customers are large organisations, such as government agencies, administrations, institutions, cities and businesses who all provide or operate systems, services and infrastructure that are vital to society in the areas of defence, security, air and rail transport, banking and telecommunications. 

Our UK operations support all of Thales’ key business sectors, including aerospace, defence, digital security, transport and space. We operate in 16 sites across all nations of the United Kingdom, with circa 7,000 employees, including highly skilled engineers, specialist functions and a range of support staff.

Thales UK procures goods and services from a wide variety of suppliers in the UK and overseas via a supply chain which, like many other organisations, is complex and multi-tiered. Thales UK also acquires significant volumes of goods and services from other parts of Thales Group, predominantly in Europe.  The diversity of those goods and services is a result of the multiple businesses within Thales UK and the global markets in which they operate. 

In 2022, Thales UK placed orders in the region of £760 million, with circa 1,400 tier-1 suppliers, 70% of which are based in UK. 

Thales UK’s Country Procurement Director is responsible for ensuring our compliance to the Modern Slavery Policy in Thales’ supply chain and the UK Chief Operating Officer for our obligations under the Modern Slavery Act. The Country Procurement Director reports directly to the UK Chief Operating Officer, who, in turn, reports to the Thales UK Chief Executive Officer. 

Thales does not tolerate modern slavery. We set a high bar for ourselves and our suppliers, deploying common procurement policies and practices across all Thales UK businesses through a single operating model, which enables standard approaches to be taken across core subjects including modern slavery.

Thales Group is required by French Law to develop a Vigilance Plan in accordance with the Duty of Vigilance Law (2017). The scope of the Vigilance Plan includes the environment, health, safety and human rights, including actions to address issues of forced labour.

To provide clarity for our supply chain partners, Thales Group has brought together the requirements of our Vigilance Plan with wide-ranging compliance issues such as anti-corruption and protection of information in our Integrity and Corporate Responsibility Charter (ICRC). The ICRC states our commitment to Human Rights as set out in the International Labour Organisation (ILO) Conventions, including the elimination of forced labour. Suppliers are requested to sign the charter to indicate their commitment to and compliance with the standards we expect of our partners.  

For Thales UK, our Modern Slavery Policy sets out requirements specific to the UK legislation, see Policy Section below.

We identify our highest risk suppliers by considering the following three elements:

1. suppliers of materials, goods or services associated with risks of forced labour
2. suppliers located in countries where forced labour is estimated to have high prevalence
3.  a level of spend which provides us with an opportunity to influence the suppliers

Existing suppliers identified as high risk are issued with a Self-Assessment Questionnaire by our third-party provider, Intertek, who review the completed questionnaires and develop corrective action plans for suppliers where necessary.  Thereafter, supplier audits can be initiated to validate progress against corrective actions.
  
In addition to signing the ICRC, where necessary potential suppliers are reviewed and referred to Intertek for further assessment via the Self-Assessment Questionnaire. Assessments may continue at periodic intervals throughout the life of the supplier contract. 
 
Thales UK updates its standard supplier terms and conditions to ensure that effective steps are taken to address issues of modern slavery. Whilst the Vigilance Plan provides us with a strong foundation for a broad range of supplier requirements across the environment, health, safety and human rights, we are keen to explore how Thales UK can further develop our approach to tackling modern slavery. Accordingly, in 2022 we engaged with Stronger Together (www.stronger2gether.org), a UK-based impact driven, not-for-profit organisation supporting business in the UK and internationally to ‘create a world where all workers are recruited responsibly and have fair work free from exploitation’.

Following a thorough review of our approach by Stronger Together, we are piloting a range of enhanced risk assessment and risk mitigation measures in one area of our business, with a view to extending the learnings across our UK business.  We look forward to reporting on this pilot in detail in our next Modern Slavery statement. Meanwhile our improvement plan moving forward includes:

• Relaunch of Modern Slavery Working Group (including additional specialist training)
• Inclusion of external expert consultant to facilitate Modern Slavery Working Group
• Further development of KPIs and reporting
• Specific training on purchasing practices for key procurement roles
• Review and update of UK Modern Slavery Policy
• Re-develop UK Supplier Standards for Modern Slavery
• Introduce new risk management process for Thales UK supply chain
• Delivery of Modern Slavery training for highest risk suppliers
• Finalise supplier assessment questionnaire taking learning from the pilot
• Distribute self-assessment questionnaire and develop corrective action plans as required – based on the results

Modern Slavery Policy (MS Policy)

The Thales UK Modern Slavery Policy can be found on our website at UK Modern Slavery and Human Trafficking Policy.

Integrity & Corporate Responsibility Charter (ICRC)

Thales requires its suppliers and subcontractors to commit and adhere to the Thales Group Integrity and Corporate Responsibility Charter, which includes a commitment to the Fundamental Principles of the International Labour Organisation. 

Thales issues a Sustainability Guide to its suppliers which includes the subject of modern slavery, the MS Policy and our expectations of suppliers.

The Thales UK internet has a dedicated Supplier page containing our Code of Ethics, Supplier Sustainability Guide and our Modern Slavery Statement.

Thales Group’s Code of Ethics

Since 2001, Thales Group has published a Code of Ethics defining the guidelines of behaviour required within the Group, including those expected towards suppliers and employees.  The Code of Ethics addresses Thales Group’s responsibility to its staff including its obligation of equality of treatment, avoiding any discrimination and ensuring respect.  It also addresses the requirement of all suppliers to comply with its principles in relation to human rights and labour standards and is fully implemented and applied within Thales UK.

Thales employees in the UK are required to refresh and confirm their knowledge of the Code of Ethics on an annual basis.

Whistleblowing Policy 

Thales UK is committed to conducting its business with honesty and integrity and encourages a culture of openness and accountability. To support this approach, we operate a “speak up” programme via the Thales Alert Line to enable issues, including concerns about modern slavery, to be reported in confidence, with the assurance that they will be investigated and appropriate action taken.

The Thales Alert Line can be used by all employees, including occasional employees of the Group (temporary or contractor) and all third parties, such as a customer or supplier of the Group or members of the general public. 

We maintain a written process setting out the actions to be taken in the event that any unethical issues, including modern slavery, is reported. 

Grievance Procedure

The Thales UK grievance procedure sets out how to deal with any grievances relating to employees’ employment fairly and without unreasonable delay.

It is the policy of Thales UK that all employees have access to a procedure to help deal with any grievances arising out of their employment. It is Thales’ aim to try to resolve all grievances informally in the first instance, and as close to its point of origin as possible. Where an informal approach does not resolve the grievance to the satisfaction of the employee, the employee may raise a formal grievance without unreasonable delay.

We believe that the risk of modern slavery in our Thales UK direct workforce is low.  Most of our business activities are technology intensive and this requires a highly skilled, professional and qualified workforce.  

When we require temporary staff in our own operations, we use a single resourcing agency that is required to comply with our supplier standards and processes set out above. 

For our wider global Supply Chain, Thales is vigilant in its approach to mitigate the risk of modern slavery. We are keenly aware of where there are areas of potential risk of modern slavery in our global supply chains; countries where the prevalence of forced labour is considered to be high and for types of purchase involving work where vulnerable workers could be exploited. These types of purchases include:

• IT & Telecomm Services
• On-site Installations
• Mechanical parts 
• Electronic components
• System & Software development
• Supply Chain Services

We refer to generally available external information, such as provided by the International Labour Organisation to identify countries of higher risk.

With regard to conflict minerals, Thales Group updated its position in early 2022 to integrate into its processes the obligations required by European regulations in force as of 1 January 2021. 

According to the European regulations, Thales is generally considered to be a “downstream user” and as such does not have a direct relationship with Conflict Minerals smelters and refiners. 

In addition, Thales is not listed on the US financial market and is therefore not subject to section 1502 of the US Dodd-Frank Act. 

Thales requires its suppliers around the world to adhere to its corporate responsibility approach by signing an Integrity & Corporate Responsibility Charter that requires them to uphold the principles of Thales’ Code of Ethics, the principles of the United Nations Global Compact and of the International Labour Organisation.

By signing the Charter, Thales suppliers and partners commit to comply with applicable laws and regulations regarding sourcing of minerals such as Tantalum, Tin, Tungsten, Gold and/or their derivatives (3TG) from conflict areas. Suppliers should exercise due diligence, as may be directed by law or regulation, on the source and chain of custody of these minerals and at a minimum require the same from the next tier of their supply chain.

Thales UK communicates its MS Policy and its position on this subject as part of the UK Ethics, Integrity and Corporate Responsibility Programme to ensure that Thales Personnel understand that this is an important matter for Thales UK. This includes:

• Procurement awareness training;
• Procurement newsletters;
• Induction training for new Procurement recruits;
• Awareness Videos i.e. Gangmasters & Labour Abuse Authority (GLAA) video;
• Intranet articles (Procurement and Ethics & Integrity pages);
• Sustainability Guide;
• CSR 2021 – 2022 Integrated Report.

Specific targeted training is provided to the Procurement function to make them aware of the MSA and to consider which parts of the supply chain from which they purchase are most susceptible to potential slavery risk. 

In 2021, a Modern Slavery e-Learning was mandated to all staff in Procurement, Human Resource, Real Estate and Health, Safety and Environment (HSE) functions.

As part of the Thales UK Sustainable Future Programme, guidance on how to identify potential slavery or trafficking issues has also been created and issued to the Procurement community.

Vigeo Eiris, Moody’s ESG Solutions, has ranked Thales Group third in its sector for Environment, Social and Governance (ESG) with an overall score characterised as “robust”.

Thales Group has been a member of the United Nations Global Compact since 2003. For the tenth successive year, our Group corporate responsibility policies have achieved Global Compact “Advanced” level, the highest level of achievement in this initiative. Through this status Thales confirms its strong involvement in key areas such as respect for human rights, the development of labour standards, the protection of the environment and the fight against corruption.  In October 2020, during the celebration of the fiftieth anniversary of the United Nations, our Chairman and Chief Executive Officer personally signed the “Statement from Business Leaders for Renewed Global Cooperation” initiated by the United Nations Global Compact.  

Thales Group remains committed to being a responsible and ethical organisation. Transparency International in its Defence Companies Anti-Corruption Index in 2015, which was the last comprehensive assessment of Defence and Aerospace companies’ ethics and anti-corruption programmes that took into account publicly available policies, procedures and commitments as well as those privately held, Thales Group ranked in Band “B”. Band “B” was the second highest rating.  Companies were placed in one of six Bands from “A” (the highest) to “F” (the lowest). Since then, Transparency International have released a 2020 index which just assesses publicly available anti-corruption policies and procedures. Thales was ranked in Band “D”. Therefore, we believe, the 2015 assessment remains the more comprehensive assessment and fuller picture of our commitment to being responsible and ethical.

In 2020, Thales Group embarked on an ISO 37001 “Anti-Bribery Management System” certification process, which was successfully completed in March 2021. Thales Group is the first French company in its sector to be certified to the ISO standard and one of the first companies in its segment worldwide on the main stock market index in France (the CAC 40) to have obtained this certification. In May 2022, the ISO standard was successfully extended to cover Thales in the UK.

ADS Human Rights Working Group: Thales UK is a member of ADS, the leading aerospace, defence, security and space trade organisation for companies in the UK. Activities are focused around the following key areas: influencing the policy debates of most importance to our industries; supporting UK manufacturing and industries’ supply chains; encouraging investments in technology and innovation and supporting business development opportunities. 

The need to consider the human rights impact of an organisation’s business activities is a subject of increasing significance for members of ADS.  Since the launch of the UN Guiding Principles on Business and Human Rights (UNGPs) in 2011, ADS members are keen to work together to articulate what the salient issues for members are and what they are doing or need to do, to respond to these issues. It is not just regulation driven but part of our collective approach to responsible businesses delivering against the UN Sustainable Development goals, in this case Sustainable Development Goal Number 8 “Decent work and Economic Growth”. 

As part of ADS, Thales sponsors approximately 30 suppliers in the SC21 programme, which is designed to accelerate the competitiveness of the UK aerospace & defence industry by raising the performance of its supply chains. This community meets frequently and Thales has communicated to this community on many issues related to sustainability, including the MSA.  

ADPG: Thales UK is represented on the Aerospace and Defence Procurement Group (ADPG), a sector wide body sponsored by the Chartered Institute of Procurement and Supply (CIPS). The mission of the ADPG is to promote co-operation and common solutions to the key challenges facing the sector and in this respect the sector response to MSA has been reviewed, together with proposals to deploy appropriate screening solutions. CIPS itself is committed to ensuring that all Procurement teams, in all businesses, put in place tools and policies to address MSA. 

MOD SPWG: The Ministry of Defence Sustainable Procurement Working Group (MOD SPWG) is a collaborative Industry and Government panel of which Thales UK is a member. The working group shares and discusses threats and opportunities within the defence industry relating to environment, economic and social issues, including modern slavery and human trafficking.
 

Thales UK considers that modern slavery and human trafficking is an abhorrent crime that inflicts unacceptable harm on vulnerable adults and children.  We fully support the principles of the UK Modern Slavery Act of 2015 and are firmly committed to its implementation.  For a company that is serious about acting responsibly, good intentions are simply not enough. Thales has recognised this for some time, progressively embedding corporate responsibility in all its business processes.

In 2022 we initiated a wide ranging, third party review of our approach with Stronger Together in order to continuously challenge ourselves to excel in our corporate responsibility commitments and develop best practices. Over the course of the next two years we are committed to going even further to address the risk of modern slavery in our business by implementing these recommendations.  

This statement was approved by the Thales UK Board on 28th June 2023 and is published in accordance with the Modern Slavery Act 2015.  This statement sets out the steps taken by Thales UK to prevent modern slavery and human trafficking in its business and supply chains during the financial year to 31st December 2022.

Dated: 28th June 2023