UK Modern Slavery and Human Trafficking Policy

Purpose and Scope

The Modern Slavery Act 2015 (MSA) consolidates offences relating to trafficking and slavery. This includes a provision for large businesses to publicly state each year the action they have taken to ensure their supply chains are slavery free. This document sets out the policy of Thales UK in relation to compliance with the MSA and the steps that it is taking to ensure compliance therewith.

Acronyms and Definitions

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

Statement

Thales UK considers that modern slavery and human trafficking is an abhorrent crime that inflicts unacceptable harm on vulnerable adults and children. It fully supports the principles of the UK Modern Slavery Act of 2015 (MSA) and has and continues to develop processes so that it does not engage in commercial arrangements with any organisation or persons that commit offences under the MSA. To assist in implementation of this policy, Thales UK includes the requirement set out in Section 4.4.1 within its supply chain terms and conditions.

Policy Provisions

The following policy provisions are included in 'Integrity & Corporate Responsibility Charter' and the 'Thales Vendor Assessment Tool' and are a requirement for all of the Thales supply chain:

1. Adherence to local and national laws
2. Freedom of workers to terminate employment
3. Freedom of movement
4. Freedom of association
5. Prohibits any threat of violence, harassment and intimidation
6. Prohibits the use of worker-paid recruitment fees
7. Prohibits compulsory overtime
8. Prohibits child labour
9. Prohibits discrimination
10. Prohibits confiscation of workers original identification documents
11. Provides access to remedy, compensation and justice for victims of modern slavery

Definitions

The MSA defines "slavery and human trafficking" as conduct that constitutes any of the  following:

• The offences of slavery, servitude and forced or compulsory labour and human trafficking in sections 1, 2 or 4 of the MSA 2015.
• The offences of slavery, servitude and forced or compulsory labour and human trafficking in sections 1, 2 or 4 of the Human Trafficking and Exploitation (Criminal Justice and Support for Victims) Act (Northern Ireland) 2015.
• The traffic in prostitution offence under section 22 of the Criminal Justice (Scotland) Act 2003.
• The trafficking for exploitation under section 4 of the Asylum and Immigration  (Treatment of Claimants, etc.) Act 2004.
• The offences of slavery, servitude and forced or compulsory labour under section 47 of  the Criminal Justice and Licensing (Scotland) Act 2010.
• Conduct that would constitute an offence in a part of the UK under any of the above provisions if the conduct took place in that part of the UK.

To assist in understanding the extent of the offences above, the following definitions have been provided by HMG Home Office:

Slavery and Servitude: Slavery in accordance with the 1926 Slavery Convention is the status or condition of a person over whom all or any of the powers attaching to the right of ownership are exercised. Since legal “ownership” of a person is not possible, the key element of slavery is the behaviour on the part of the offender as if he/she did own the person, which deprives the victim of their freedom. Servitude is the obligation to provide services that is imposed by the use of coercion and includes the obligation for a “serf” to live on another person’s property and the impossibility of changing his or her condition.

Forced or Compulsory Labour: Forced or compulsory labour is defined in international law by the International Labour Organisation’s (ILO) Forced Labour Convention 29 and Protocol. It involves coercion, either direct threats of violence or more subtle forms of compulsion. The key elements are the work or service is exacted from any person under the menace of any penalty and for which the person has not offered him/herself voluntarily.

Human Trafficking: The offence of human trafficking requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. The offence can be committed even where the victim consents to the travel. This reflects the fact that a victim may be deceived by the promise of a better life or job or may be a child who is influenced to travel by an adult. In addition, the exploitation of the potential victim does not need to have taken place for the offence to have been committed.

Modern Slavery Statement

It is a requirement of the MSA that Thales UK, as a commercial organisation, which supplies goods or services and has a minimum total turnover of £36 million per year, prepares a slavery and human trafficking statement for each financial year. The MSA Statement is to be  issued as soon as possible after the end of its financial year, but in any event within the six months following the end of that financial year.

The MSA Statement is to be approved by Thales UK’s Board and is to be signed by the UK CEO and UK Chief Procurement Officer, to ensure that the statement, due diligence and governance mechanisms to be applied within Thales UK receive the appropriate level of strategic consideration.

The MSA Statement is to be published on the Thales UK internet site with a prominent link on its home page to the statement. The Home Office Guidance on MSA recommends that the link should be entitled: “Modern Slavery Act Transparency Statement”. All parts of Thales UK having their own intranet sites must also include a prominent link on their home page to the Thales UK MSA Statement.

The MSA Statement is to include the steps Thales UK has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business or that, Thales UK has taken no such steps.

It is recommended by the MSA that the MSA Statement includes information about:

• Thales UK’s structure, business and its supply chains.
• Its policies in relation to slavery and human trafficking.
• Its due diligence processes in relation to slavery and human trafficking in its business and supply chains.
• The parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk.
• Its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators, as it considers appropriate.
• The training on slavery and human trafficking available to Thales Personnel.

In order to meet the principles set out in the MSA, Thales UK has implemented the following actions within its businesses in the UK:

Third Party Due Diligence

As part of Thales UK’s screening of Associated Persons in accordance with the UK Bribery Act, an assessment will be made of supplier third parties in relation to the principles of the MSA.

Risk Assessment

Thales UK requires a Risk Assessment, to identify the highest risks of modern slavery in our organisation and our supply chains. The Risk Assessment includes Sectors, Categories and Types of Work and identifies any potential worker groups that can be considered vulnerable and types of work or hazardous and high-risk sectors. See 'Acronyms and Definitions'.

Integrity & Corporate Responsibility Charter

Thales UK requires all new and legacy suppliers to sign its Integrity & Corporate Responsibility (ICR) Charter. The ICR Charter specifically addresses human rights, employment practices, anti-corruption, other legal practices (including competition & anti-trust, insider trading, and fraud & deception), conflicts of interest, maintenance of accurate records and audit rights, protection of information, environment, health & safety, global trade compliance and the requirement to operate an ethics and compliance program requirements.

The relationship between Thales Partners and Suppliers is an important component for building sustainable business success. Thales expects from its Partners and Suppliers full compliance with all applicable laws and regulations of the countries where they are registered, as well as where operations are managed or services provided. 

In this respect, the Thales Partners and Suppliers ICR Charter represents a minimum standard of best practice. For the purpose of the Thales ICR Charter, Partners and Suppliers shall encompass suppliers, sub-contractors, distributors, resellers, or any company with which Thales enters into a partnership agreement (such as a member of consortium, a member of an economic interest grouping, a shareholder in a joint venture or a non-profit organization).

The ICR Charter includes provisions relating to the following:

• Adherence to local and national laws
• Freedom of association
• Prohibition of any threat of violence, harassment and intimidation
• Prohibition of child labour
• Prohibition of discrimination

Conditions of Purchase

Thales UK has implemented the following standard condition within its supplier contracts:

“Thales suppliers shall perform the required due diligence to comply with the requirements of the Modern Slavery Act 2015 to ensure that their supply chains are free of Human Trafficking and shall provide written confirmation to Thales that they have done so. Thales has the right to audit your due diligence procedures to confirm the steps you have taken to comply with the Modern Slavery Act 2015.”

Thales Vendor Assessment

The Thales UK vendor assessment tool includes a section on modern slavery and human trafficking to establish whether the supplier complies with the MSA and has implemented appropriate controls of their own supply chain in this area.

These include requests for information in relation to the following items to which all its suppliers are to respond:

• its due diligence processes in relation to slavery and human trafficking in its business and supply chains;
• the parts of its business and supply chains where there is a risk of slavery and human  trafficking taking place, and the steps it has taken to assess and manage that risk;
• its effectiveness in ensuring that slavery and human trafficking is not taking place in its  business or supply chains.

Vendor Certification

Thales UK requires direct suppliers to certify that materials incorporated into the product being supplied, comply with the MSA and the laws and regulations of the country or countries within which they are operating.

Vendor Accountability

Thales UK makes it clear to its suppliers that there are serious repercussions where suppliers do not comply with Thales UK’s requirements in relation to the MSA.

Documentation

Thales UK has amended the procurement documents referenced in 'Applicable Documents' to include statements on modern slavery and human trafficking.

Supplier Communications

Thales UK takes the opportunity at all appropriate supplier meetings to communicate Thales UK’s policy on modern slavery and human trafficking and the importance for suppliers to perform due diligence on their own supply chain, to ensure that they are not in breach of the MSA.

All Buyers are instructed to ensure that their current or potential suppliers are made aware of  the requirements of the MSA and Thales UK’s policy in respect thereof.

The Thales UK external web page for suppliers includes a section on the MSA and Thales UK’s requirements in relation thereto.

Thales Alert Line

The Thales Alert Line platform is intended to receive reports concerning any of the conduct or situations listed below, transmitted by an individual acting in good faith. This includes, for instance and not limited to, internal or external employees, occasional employees of the Group (temporary or contractor), a third party individual (such as an employee and not limited to) of a customer or supplier of the Group. 

1. Human Rights abuse
2. Harassment/Discrimination/Workplace Violence
3. Data protection issues
4. Bribery or influence peddling
5. Fraud
6. Money laundering, financial and accounting crimes
7. Conflicts of interest
8. Anti-competitive practices
9. Trade compliance 
10. Product Safety
11. Health and Safety
12. Information Security and Privacy
13. Environmental Issues

Supplier Awareness

As part of its supplier awareness, Thales UK communicates to suppliers on a regular basis on a number of procurement related topics including the MSA and its implications.

Supplier Audits

Thales UK will test compliance with the MSA when carrying out a third party audit of a supplier who is identified as at risk of modern slavery.

Awareness Training of Thales Personnel

Thales UK raises awareness for Thales Personnel on the principles of the MSA and its position on this subject as part of its mandated Ethics & Integrity Programme. Procurement, HR, HSE and Real Estate functions receive increased levels of awareness, together with targeted training. Training is continually reviewed and updated accordingly to meet business and audience needs. 

Awareness Communications to Thales Personnel

Thales UK will maintain regular awareness communications relating to its policy on Modern Slavery and Human Trafficking and its position on this subject as part of the UK Ethics & Integrity Programme to ensure that all Thales Personnel understand that this is an important matter for Thales UK.

Signed for and on behalf of Thales UK by

Dated 6th June 2022