Modern Slavery & Human Trafficking Statement

Our commitment

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced or compulsory labour, debt bondage and human trafficking, all of which deprive a person of their liberty for another's gain.

We have a zero-tolerance approach to modern slavery in any part of our business or supply chain. We are committed to acting ethically and with integrity, to implementing and enforcing effective systems and controls, and to upholding the standards reflected in the Modern Slavery Act 2015, the International Labour Organization (ILO) core conventions, and the United Nations Guiding Principles on Business and Human Rights.

About this statement

This statement relates to the financial year ending [CONFIRM]. The Modern Slavery Act 2015 requires a slavery and human trafficking statement from commercial organisations with an annual turnover of £36 million or more; where our turnover is below that threshold, we publish this statement voluntarily as a matter of good practice and to give our customers, partners and suppliers confidence in how we operate. It is reviewed and updated annually.

Our business and structure

Hawke Electric Vehicles is a trading name of The Hawke Group Ltd, a company registered in England and Wales under company number 16624766. Our registered office is 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ. References to "we", "us" and "our" mean The Hawke Group Ltd. We design, configure, assemble, sell, hire and service electric vehicles — including golf buggies, people movers and utility vehicles — for clients in the United Kingdom and internationally. Our team, operations and management are based in the United Kingdom.

Our supply chain

Our vehicles are primarily assembled, configured and finished in the United Kingdom. Some vehicles, components and parts are sourced from manufacturing partners overseas before being assembled, quality-checked and finished here. Our supply chain therefore includes UK assembly and finishing operations together with a number of established overseas component and vehicle manufacturers.

We regard the parts of any supply chain involving overseas manufacturing as carrying a higher inherent risk, and we focus our due diligence accordingly. We expect every supplier and manufacturing partner — in the UK and overseas — to share our commitment to lawful, safe and fair working conditions, and to comply with all applicable employment, health-and-safety and anti-slavery laws.

Supplier oversight, audits and inspections

To manage the risk of modern slavery in our supply chain, we take the following steps:

• We seek to work with established, reputable manufacturing partners and to build long-term relationships that allow proper oversight.
• Our overseas manufacturing partners and factories are subject to regular inspection and audit — including, where appropriate, site visits, social-compliance/ethical audits, and review of working-hours, wage, age-verification and labour-rights records.
• We expect suppliers to cascade equivalent standards to their own suppliers and sub-contractors, and to allow us, or an independent auditor acting for us, a right to audit.
• We include, or are progressively including, anti-slavery and human-rights obligations in our supplier terms, and we reserve the right to suspend or end a relationship with any supplier who fails to meet them or to cooperate with remediation.
• Where we identify a concern, our approach is to require corrective action and verify it, escalating to termination where a supplier is unwilling or unable to remedy a serious issue.
• [CONFIRM — owner: confirm the exact audit/inspection cadence, who carries them out (in-house or named third-party auditor), and the standards applied, so this section reflects what actually happens.]

Our policies

Our approach to modern slavery is supported by our wider policies, which together reinforce our zero-tolerance position:

• A whistleblowing channel, so that staff, suppliers and others can raise concerns about wrongdoing — including suspected modern slavery — without fear of reprisal.
• A supplier code of conduct / supplier expectations setting out the labour, safety and human-rights standards we require.
• Recruitment and employment practices designed to ensure all workers are legally entitled to work, are recruited fairly and freely, are paid at least the legal minimum, and are not subject to unlawful deductions or withheld documents.
• A commitment to act on, and where appropriate report, any credible evidence of modern slavery to the relevant authorities.

Risk assessment and due diligence

We assess and review the modern-slavery risk in our operations and supply chain, taking into account the country and sector of our suppliers and the nature of the work involved. Higher-risk relationships — for example overseas manufacturing — receive proportionately greater scrutiny through the audits, inspections and contractual measures described above. Due diligence is carried out before we onboard significant new suppliers and on an ongoing basis thereafter.

Training and awareness

We raise awareness of modern slavery among our staff, particularly those involved in procurement and supplier management, so they can recognise the warning signs and know how to escalate a concern. [CONFIRM — owner: describe the training you actually provide, e.g. induction briefing and periodic refreshers for relevant staff.]

Measuring our effectiveness

We monitor the effectiveness of these measures using indicators such as the proportion of key suppliers covered by anti-slavery obligations and audits, the number and outcome of supplier audits or inspections, whistleblowing reports received and how they were resolved, and completion of staff awareness training. We use what we learn to improve our approach each year.

Approval

This statement was approved by the board of directors of The Hawke Group Ltd and is published with their authority. It will be reviewed and updated annually. Signed by [CONFIRM — director name], [CONFIRM — role, e.g. Director], for and on behalf of The Hawke Group Ltd. Date of approval: [CONFIRM]. Questions about this statement can be sent to legal@hawkeev.com.