Modern Slavery Act Statement

Modern slavery act 2015: slavery and human trafficking statement

This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 (the Act) and sets out the steps that FIH group plc has taken to ensure that slavery and human trafficking is not taking place in its supply chains or any parts of its business.

Organisation's structure

We are FIH Group plc, a provider of retail, property rental, freight, automotive, ferry and art handling and logistic services. We are the parent company of the Falkland Islands Company Limited, the Falkland Islands Trading Company Limited, Falkland Islands Shipping Limited, Erebus Limited, South Atlantic Support Services Limited, Paget Limited, the Portsmouth Harbour Ferry Company Limited, Portsea Harbour Company Limited, Clarence Marine Engineering Limited, Gosport Ferry Limited, Momart International Limited, Momart Limited and Dadart Limited (Group). The Group has over 335 employees and operates in two countries.

In the year ended 31 March 2018, the Group had a global annual turnover of £43,830,000.

Our business

Our business is organised into 9 business units: Retail, Property and Construction, Freight and Port Services, Support Services, Property Rental, Automotive, Ferry Services, Cruise Services and Art Handling and Logistics.

Our supply chains

We aim to only work with partners who share our ethical values and will keep our supply chain under constant review.

The diverse nature of the group is reflected in the great variety of goods and services provided by our suppliers. Goods acquired include food, vehicles, home furnishings, furniture, clothing and building materials for retail and own use. We use a number of agents across the globe for provision of logistics services and have a number of service providers including those providing legal, IT and HR support services.

With the exclusion of Momart’s international logistics partners, the majority of our suppliers are based in the UK and are therefore deemed to be at a lower risk of modern slavery than if they were based overseas. Momart’s international suppliers are largely based in first world countries with similar Modern Slavery legislation as that in operation in the UK. Momart’s main overseas suppliers are either major airlines or members of ARTIM, a trade association for the premier fine art logistics companies from around the world who serve the world’s leading museums and galleries and are subject to the high levels of due diligence carried out by those customers. They are therefore deemed to be at low risk of having modern slavery in their supply chains in respect of the services provided to this group.

Our policies on 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. We are committed 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 out supply chains.

Due diligence processes for slavery and human trafficking

During the year the group developed a new Ethical Business Policy and Code of Conduct Statement, This reiterates the commitment of the group to maintain the highest standards of ethics and integrity in conducting its business and to operate legally, honestly and fairly across all the businesses. This policy includes the commitment to require suppliers to adhere to requirements concerning data protection, modern slavery and anti-bribery.

A new modern slavery policy has been written for distribution to all staff.

New staff will be issued with a copy of both the ethical business policy and the modern slavery policy as part of their onboarding process.

As part of our initiative to identify and mitigate risk we have collated information on suppliers across all areas of the group and begun work risk assessed them based on activity, geography and information available on their own modern slavery procedures.

New suppliers will be issued with a copy of the modern slavery policy as part of the procurement process. Modern slavery compliance clauses have been drafted for inclusion in formal contracts and a due diligence questionnaire is being drafted which will be sent to any new suppliers.

A supplier code of conduct has also been drafted which requires suppliers to adhere to the same principles as the group in respect of ethics and integrity and legal compliance. The code of conduct includes requirements concerning data protection, anti-bribery, anti-money laundering, health and safety as well as including the modern slavery policy. Once approved by the board, this will be issued to all suppliers by the relevant operating entity.

Where new or existing suppliers are deemed to be at a higher risk of having modern slavery practices within their supply chain, a due diligence questionnaire will be sent to them for completion.

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we are developing a supply chain compliance programme. The Board of FIH Group plc and the Board of each of its subsidiaries has ultimate responsibility for implementation of the Group’s policies, including those that relate to slavery and human trafficking.

Modern Slavery Act compliance will be made a standing agenda item for all operating divisions to monitor progress in carrying out due diligence across the supply chain.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, a training program is being developed for those staff involved in procurement. In additional all staff will be reminded of the expectation that they should report any suspicious activity.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 31 March 2018. It has been approved by the FIH group plc board of directors.

John L Foster
Group Chief Executive

Operating Companies