Organisation

This statement applies to Hallite Seals International Ltd (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 2020.

Organisational structure

We are part of the Michelin Group and our ultimate parent company is Compagnie Générale des Establishments Michelin, headquartered in Clermont-Ferrand, France.
Our Organisation is based in Hampton, United Kingdom and a further seven countries.

The main activity carried out by the Organisation is manufacture of polymer and rubber seals mainly to OEMs in areas that include agriculture, construction and infrastructure, mining, off highway, general industrial and material handling, and aerospace.

The labour supplied to the Organisation in pursuance of its operation is carried out in accordance with country specific HR Policy, generally with directly employed labour or on occasion temporary labour supplied through a recognised employment agency. In both cases complying with local labour laws for their terms and conditions.

Definitions

The Organisation considers that modern slavery encompasses:

  • human trafficking
  • forced work, through mental or physical threat
  • being owned or controlled by an employer through mental or physical abuse of the threat of abuse
  • being dehumanised, treated as a commodity or being bought or sold as property
  • being physically constrained or to have restriction placed on freedom of movement

Commitment

The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in Germany, Italy, USA, Canada, India, China and Australia and in many cases exceeds those minimums in relation to its employees.

Supply chains

In order to fulfil its activities, the main supply chains of the Organisation include those related to polymer and rubber raw materials.

Due diligence is taken to ensure supply of raw material meets our strict policy and in general, the Organisation considers its exposure to slavery/human trafficking to be zero and it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

Impact of COVID-19

During the reporting period covered by this statement, the COVID-19 pandemic had taken hold. For several months, the UK was placed into lockdown to stem the spread of COVID-19. This created several challenges for the Organisation, as it did for others across the nation.

The Organisation noted the UK Government’s decision, as confirmed in April 2020, to allow for a delay of up to 6 months. Despite the permitted, delay, the Organisation remains in a position to publish this statement.

The Organisation concludes that the COVID-19 pandemic did not adjust the risk of modern slavery to a level above that which existed before the pandemic.

During the pandemic, the Organisation’s employees still had access to the grievance procedure to raise any concerns that they may have had. In addition, during 2020 we implemented a new whistleblowing reporting line to mirror the Michelin guidelines which were duly published to all employees.

The Company operated throughout the pandemic and the Organisation’s modern slavery risks were subject to the same monitoring procedures during the pandemic as at all other times.

Steps

The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review and audits of the controls of its suppliers.

The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

Policies

The Organisation has a suite of policies which further define its stance on modern slavery including HR Policies, Code of Ethics and Code for Anti-Corruption.

Slavery Compliance Officer

The Organisation has an HR Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Date of approval: 15 January 2021