Modern Slavery Statement

Hawthorn Timber Modern Slavery and Human Trafficking Statement 2022/23

Policies in Relation to slavery and Human Trafficking

The Hawthorn Timber Ltd Modern Slavery and Human Trafficking Policy has been prepared in order to give guidance and instruction to the minimum and recommended standards acceptable to Hawthorn Timber Ltd in the manufacture of their products. Vendors are expected to comply with national and other applicable law and where the provisions of the law and the contents of this document address the same subject, to apply to provision with affords the greater protection.

The Hawthorn Timber Ltd Ethical Compliance Requirements for Vendor Approval procedure clearly describes the process all stakeholders must complete for the Hawthorn Timber Ltd Ethical Team to approve a factory.

Hawthorn Timber Ltd is committed to ongoing and continual improvement, training and capacity building in the area of ethical trade, with measurable targets set annually as part of its broader performance review and as a fundamental part of its commitment to ETI membership.

Risk assessment and Mitigation

All vendors must agree to the principles of the Hawthorn Timber Ltd Ethical Guide for Vendors in all new contracts.

In line with ETI Human Rights and Due Diligence Framework, Hawthorn Timber Ltd adopt several methods to asses and manage risk throughout our operations.

Risk categorization primarily focuses on risk to vulnerable workers and considers country, region and industry using information published by global NGO’s. Our priority is to those workers in high risk situations where we can make the biggest positive difference to their welfare.

High risk vendors must accommodate a social compliance audit and resolve improvement areas to an agreed timeframe. This applies top Tier 1 sites and beyond when necessary. Vendors are encouraged to establish and improve on their own processes and asses risks within their supply chain.

Medium and low risk vendors must submit copies of their own audits or complete a SAQ.

Training on the Modern Slavery Act is deployed to vendors, across all supply chains to raise awareness of the issue.

On-site health and safety training is conducted at high risk sites. We plan to extend the reach of the training to more sites.

Hawthorn Timber Ltd raised organizational awareness through specific learning and development training for colleagues.

During 2022, specialized training was provided to Hawthorn Timber Ltd colleagues deemed most at risk demographically. The training received excellent feedback and will be extended to more colleagues.

Due Diligence

As part of our existing due diligence processes, regular assessments of new and existing factories are conducted. Several methods are employed to conduct due diligence, with most resource given to high risk supply chains.

During 2022, and in line with industry guidance to reduce the reliance on audit, we increased the remit of factory visits by our trained procurement and ethical teams. The teams are trained to recognize the signs of Modern Slavery and exploitation and consult with the ethical team on their observations.

Our quality control teams use time spent at the factory to observe changes in both the demographics and culture and report back when necessary. High risk vendors, including those high spend and business critical vendors to Hawthorn Timber Ltd continue to receive regular audits. The frequency of the audits reduces as trust develops between organisations.

High risk vendors with a vulnerable workforce such as low-paid or high proportion of migrant workforce are given additional focus to ensure good practice is followed.

During 2023 we will consider a beyond audit approach for high risk vendors, collaborating with our ethical partners, to work in the community on our behalf.

Effectiveness of Our Policies and Processes

The Hawthorn Timber Ltd Main Board receive reports detailing the performance of our supply chain and own business in relation to ethical trade, modern slavery and human trafficking.

The reports include performance against agreed key performance indicators (KPI’s) across six measures relating to the International Labour Organisation (ILO) Labour Standards.

Granularity includes country and industry sector and by exception, individual factories should issues be identified. Our performance is measure against global and industry benchmarks conducted at similar factories. All areas of concern are investigated and explanations submitted.

For specific high risk issues, further investigation may be sanctioned, including further factory visits or audits. In extreme cases, and when all other courses of action considered, the removal of a vendor from the approved vendor list is required.

Continuous improvement is important and for transparency we have shared several of our targets for 2023 in the table below. The observations made by Hope for Justice have been incorporated into our action plans for 2022/23, along with extracts from our strategic plan.

Training and Capacity Building

Hawthorn Timber Ltd is committed to continuous improvement through training. Hawthorn Timber Ltd colleagues are provided with Ethical Trade and Modern Slavery training relevant to their roles.

Forms of training including: internal and external classroom, online learning and development, one-to-one coaching and conferences hosted by our ethical and sustainable partners.

Hawthorn Timber Ltd are now an active member of the Ethical Trade Initiative (ETI) Modern Slavery Working Group.

During 2023, further training is planned, with specific focus on responsible sourcing for our procurement and category teams and further modern day slavery training for Hawthorn Timber Ltd colleagues.

Training provided for our vendors will continue throughout 2023 and we will continue to offer our vendors the chance to attend training sessions hosted by relevant providers.

Thought Leadership and Collaboration

Hawthorn Timber Ltd are proud to take a leadership approach to our stakeholders and wider community. We firmly believe sharing knowledge and experience of ethical trade and modern day slavery raises awareness across all communities and is a key step in a patch to the eradication of slavery.

On an ongoing basis, we present our approach to modern day slavery and ethical trade to organisations including customers, their suppliers, sustainability consortia and Health, Safety and Environmental Groups.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Hawthorn Timber Ltd Slavery and Human Trafficking Statement.