Hanwha Vision Europe Limited ("Hanwha", "we", "our" or "us") is committed to preventing modern slavery and human trafficking in all aspects of our business and supply chain. This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 and sets out the steps we take to identify, assess, and mitigate risks related to modern slavery during this reporting period, the financial year 2026/27.
Hanwha Vision Europe Limited is part of the Hanwha Group, a global organisation headquartered in South Korea. In Europe, we operate from our registered office at: Heriot House, Heriot Road, Chertsey, Surrey, KT16 9DT, United Kingdom.
In Europe, we do not manufacture any products. We specialise in the provision of goods made in our factories in Vietnam and South Korea. Specifically, we provide advanced video surveillance and security solutions across a range of sectors. We work with third-party distributors, systems integrators and logistics providers as part of our supply chain.
We employ skilled professionals across sales, technical, operational, and support functions. Our direct operations are predominantly office-based, and we consider the risk of modern slavery in our direct workforce to be low as a result.
However, we recognise that potential risks may arise within our wider supply chain, particularly in areas such as manufacturing, logistics, and component sourcing.
We therefore adopt a risk-based approach to identifying and managing modern slavery risks, taking into account geography, sector, and potential vulnerability of workers.
Hanwha also considers whether its purchasing practices, commercial arrangements, business model or relevant performance targets could contribute to modern slavery risks within its operations or supply chain.
Hanwha is committed to conducting business ethically and with integrity. We maintain a zero-tolerance approach to modern slavery and human trafficking and expect the same high standards from all our business partners.
We operate in compliance with laws and regulations including, but not limited to, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and the UN Convention on the Rights of the Child.
We maintain internal policies that support ethical conduct, including:
These policies reinforce our commitment to respecting human rights and ensuring responsible business practices.
We are committed to ensuring transparency within our supply chain. Our procurement and supplier onboarding processes include:
We expect all suppliers to:
Where concerns are identified, we will engage with suppliers to seek an appropriate, timely and victim-centred remediation. This includes the immediate protection of affected workers, thorough investigation and escalation where necessary, and engagement with relevant specialist organisations and authorities where appropriate.
Where the supplier fails to address these concerns, or where remediation is not possible or effective, business relationships may be terminated. Any decision to terminate will take into account the potential impact on affected workers and the risk of further harm.
Additionally, Hanwha expects suppliers and labour providers to take appropriate steps to prevent recruitment practices that could create risks of forced labour or debt bondage.
In addition to supply chain due diligence, Hanwha has also implemented the Smart Grievance Centre Operating Process, through which employees and workers within our supply chains can raise concerns about modern slavery or other related issues themselves. Reports are addressed appropriately and workers are protected during this process.
We are committed to raising awareness of modern slavery risks within our organisation. Targeted training is provided to employees involved in procurement, supply chain management, and contract oversight to ensure they are equipped to identify and respond to potential risks. Training is reviewed periodically to ensure it continuously meets our standards, and employee completion of this training is monitored.
Hanwha will continue to review and enhance its policies, procedures, and controls to mitigate the risk of modern slavery. We are committed to continuous improvement and to working collaboratively with stakeholders to uphold human rights across our operations and supply chain.
During the reporting period, Hanwha did not identify any confirmed incidents of modern slavery within its supply chain or within our own operations. Despite this, we will continue to monitor the effectiveness of our approach, so that we may continue to maintain a high standard of employee wellbeing.
Hanwha Vision Europe Ltd. are publishing this tax strategy for the 2024 financial year to comply with their duty under paragraph 16(2) Schedule 19 of the UK Finance Act 2016.
We (Hanwha Vision Europe) act responsibly in all out tax matters, recognising the importance of paying the right amount of tax. We take an objective view of the generally understood interpretation of the relevant laws and regulations. We seek to build constructive relationships with tax authorities in the UK and provide transparent disclosure to ensure that all our stakeholders are well informed about out tax matters.
Hanwha Vision Europe Limited ("HVE") is a wholly owned subsidiary of Hanwha Vision Company Ltd ("HVW"), a company incorporated in South Korea, and a member of the Hanwha group of companies.
HVE's principal business is the purchase of CCTV and security products from its parent and the sale of these products via distribution throughout Europe and Turkey.
HVE is committed to complying with all aspects of UK tax law and practice. Compliance means ensuring the correct amount of tax is paid at the right time and all tax returns are submitted to HMRC in accordance with due dates.
This approach applies to all UK taxes applicable to HTE's operations including corporation tax, VAT and payroll taxes.
We endeavour to contribute to the national economy and social development through improving productivity, job creation, faithful tax payment, and making contributions to society.
Ownership of our tax strategy, as with the wider business strategy, rests with Hanwha Group's board and HVW in general. The day-to-day responsibility for tax rests within HVE, as taxes by their nature are levied on legal entities rather than on the Hanwha Group or HVW as a whole.
HVE and its parent company share a low risk approach to tax governance, and adhere to internationally accepted laws and regulations. If a risk is identified either in relation to compliance or the understanding of complex tax requirements, professional external advice is obtained.
HVE's Chief Financial Officer is responsible for the company's compliance with UK tax requirements and for the management of their tax risks. The finance team together with external professional advisors provide support to the CFO in relation to the preparation of tax returns, and observing and implementing changes to UK tax law.
HVW's Compliance Team in Korea monitor HTE's tax compliance and tax risk on a regular basis. Any risks thought to be significant are reported to the Board of Directors and to the Audit Committee. CFO provides updates on material tax matters as part of the regular updates to HVW and Hanwha Group's board.
HVE has a conservative approach to taxation issues and seeks to ensure its tax affairs reflect the regulatory, legal and commercial environment in which its business operates. All decisions are taken after careful consideration of all the issues and potential impacts. HVE does not employ aggressive interpretation of the tax law, or partake in tax avoidance schemes which are contrary to the intention of the law.
The external tax advisers are consulted to provide advice on commercial transactions to identify risks and ensure tax compliance.
HVE's operations are closely linked with that of its parent company, in particular through the purchase of goods for resale, product development and shared services such as the IT systems.
HVE is the representative of HVW's business interests in the UK and Europe. HVE receives tax advice from our tax teams in Hanwha Group, HVW, and country level comprising individuals with a mix of industry and business knowledge and subject matter expertise, in order to ensure any tax implications of these operational arrangements such as transfer pricing, are adequately addressed to ensure both companies are compliant with UK tax requirements at all times. From time to time we engage external tax advisers to provide specialist expertise, to provide second opinions on significant transactions, and to help us with insight on industry practice. This situation is closely monitored both by HTE's Chief Financial Officer and finance team, and HVW's compliance team.
We understand our tax affairs are complex, given the range of taxes that apply to our businesses and the cross-border dimensions that come from being an international group.
HVE has an open and transparent relationship with HMRC and endeavours to communicate with honesty, integrity and in a co-operative and professional manner, and enhancing mutual trust and cooperative relationships. If a situation arises requiring clarification or interpretation of a complex tax matter, HVE will aim to work pro-actively with HMRC to ensure HVE adopts the most appropriate treatment.
The Companies (Miscellaneous Reporting) Regulations 2018 applies to accounting periods beginning on or after 1 January 2019. It requires directors to explain how they considered the interest of key stakeholders and the broader matters set out in section 172(1) (A) to (F) of the Companies Act 2006 ('S172') when performing their duty to promote the success of the company under S172.
This S172 statement explains how the directors:
Have engaged with employees, suppliers and others; and Have had regard to employee interests, the need to foster the company's business relationships with suppliers, customers and other partners, and the effect of that regard, including on the principal decisions taken by the company during the financial year.
The S172 focuses on matters of strategic importance to the company and the level of information disclosed is consistent with the size and complexity of the business
The directors understand the business and the dynamic environment in which it operates. They appreciate the necessity to consider the long term consequences of their decisions not only on the company but its stakeholders.
The company's key values are:
Challenge - Pursue excellence through change and innovation by breaking away from complacency
Dedication - Treasure the relationships with colleagues, company, and customers and commit to achieving a greater goal
Integrity - Stick to principles, be impartial and take pride in doing so
The directors consider that the key to long term success is by adhering to these key values when making decisions, and thus strengthening the brand's reputation with its stakeholders. They understand that sustained growth is dependent on their relationships with their stakeholders and the strong reputation of its brand.
By applying the company's three key values and considering the long term consequences of their decisions, the directors expect to continue to add value to the company.
The directors recognise that employees are fundamental to the business and the delivery of its strategic ambitions. The success of the business depends on attracting, retaining and motivating employees, by ensuring that the company remains a responsible employer, from pay and benefits to health and safety. The directors factor the implications of decisions on employees where relevant and feasible.
The company's policy on recruitment is based on the ability of a candidate to perform the job. Full and fair consideration is given to applications for employment from disabled people where they have the appropriate skills and abilities to perform the job. All necessary training and assistance is given to enable disabled employees to perform their duties. If employees become disabled during their employment, consideration will be given to retraining and redevelopment.
During the financial year monthly information bulletins were sent to all employees giving information of matters that were likely to concern them. Weekly management meetings were also held giving managers the opportunity to share the views of their staff regarding decisions which were likely to affect employees' interests. There is no employee share scheme at present.
In addition during the weekly management meetings information was shared regarding the financial performance of the company, and the general economic and market factors which were affecting the business. The managers were encouraged to share this information with their teams.
The directors engaged with employees throughout the year by means of attending the weekly management meetings described above. Also, a bi-annual newsletter from the managing director was sent to all employees giving details of the financial performance and the economic factors concerning the business, together with news of any key decisions and developments proposed by the company.
Delivery of the company's strategy requires strong relationships with all key stakeholders including suppliers, customers, employees and regulatory bodies. Key stakeholders are identified as those having the most influence over the success of the business. The company promotes the spirit of trust and loyalty and the application of its three key values of Challenge, Dedication and Integrity to each of these relationships. The directors receive information and reports from all key departments within the business on a range of subjects including product and supplier contract management, and project opportunity and customer contract management.
The company's sales teams have direct contact with the customers and they gather feedback and information about customer needs and requests, which are turned into Voice of the Customer (VOC) reports. These VOC reports are taken into consideration when planning and developing products. In addition to this our managing director visited key customers throughout the year to discuss business plans and strengthen business relationships.
We are in constant contact with our suppliers to discuss current demand, delivery dates and possible product developments. The directors realise that good relationships with the company's suppliers is of vital importance to the business.
The directors took regard of customer, supplier and other interests when making the following principal decisions during the financial year.
Our directors are aware of the current concerns regarding the impact of business on the environment. As purely a distribution company our operations do not directly have a significant impact on the community or environment. Our products are sourced from our headquarters in Korea. They have implemented sustainable management practices on the environment, safety, health, energy and greenhouse gas issues under the guidance of the Hanwha Eco-institute. Locally, the company have reduced waste at its European headquarters by introducing a recycling policy for waste paper, batteries and computer toner cartridges, and by switching their company fleet to hybrid cars.
It is important to the company to maintain its spirit of trust and loyalty. The directors periodically review the company's approach and policies regarding ethics and compliance, modern slavery, GDPR and cyber security, to ensure that its high standards are maintained within the business and its business relationships. The key values of challenge, dedication and integrity are promoted throughout the workplace to highlight the behaviour that the company expects from all employees. A whistleblowing policy is in place so that employees can report any conduct that does not comply with the company's high standard of business conduct.
After considering all relevant factors, the directors consider which course of action best enables delivery of its long term strategy, taking into consideration the impact on stakeholders. In doing so, the directors act fairly between the company's members but in doing so this means that certain stakeholders' interests may not be fully aligned.
The directors took regard of stakeholders interests when making the following principal decisions during the financial year:
(i) 2022 Business Plan - When approving the company's business plan for the year the directors took regard to the company's vision of providing premium security products with high performance, high resolution and high stability to create new social values of safety and reliability, and working for customer trust, and respect from the people who live in communities where they operate.
The review included engagement with key stakeholders including management from the company's European branch offices who provided information about their local customers' requirements. The directors engaged with suppliers and key partners, and reviewed recent regulatory and government guidelines, to ensure the plan's effectiveness to enhance cyber security and provide improved technology and features for their products. It considered its operations effects on local communities and the environment with a view to how the plan could provide improvements.
The directors also reviewed information regarding the organisational structure and employees, with particular attention to salaries, employee benefits, incentives, health, safety and training.
All managers were consulted regarding the setting of key metrics against which all employee bonuses were to be calculated for the year. The metrics were discussed at length to ensure they would motivate and support the correct culture within the business, while also aligning with the company's strategy.
The directors concluded that the final business plan for 2022 underpinned the long term strategy for the company, while also taking into account different stakeholder views, realising that not all stakeholders views can or will completely align with the company's plan.
(ii) New Pricing Policy - The decision was taken during 2022 to align the business' pricing policy across all territories. Previously there were 9 different pricing policies in existence across its different European sales regions. This was difficult to administer and made it impossible to keep a uniform market price across Europe.
Before taking the decision the directors considered the impact that it would have on the company's stakeholders.
As a result of the levelling up of the pricing structure, the distributors' margin would fall in most regions. However, to incentivise distributors to play a more active role they would receive a larger margin for any projects where they managed and specified our products. Also the uniform pricing across regions would be welcomed by the pan European distributors as the same pricing would be applicable across all their European branches. It was felt that despite some objections, overall the distributors would find the new pricing policy acceptable.
It was expected that the effect on our STEP partners would be positive as the new pricing policy would give them more competitive pricing, and quicker handling of project pricing decisions.
The decision was also anticipated to positively impact our employees. There would now be one pricing policy for all customers which would be easier to administer, and simplify the calculation of STEP partner rebate claims.
The directors concluded that their decision to implement the new pricing policy while likely to meet with some resistance, was expected to have a positive effect on the market and the majority of the company's stakeholders.