Modern slavery and human trafficking statement

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Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking. These have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. Ultra Electronics and its subsidiaries (“Ultra”) has a zero-tolerance approach to modern slavery.

Ultra is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery does not take place anywhere in its business or in any of its supply chains.


Our structure

Ultra Electronics Holdings plc is the group parent company. Its head office is in the UK and it also has other global offices and facilities, predominantly in the USA, Australia and Canada.


Our businesses

Ultra is organised into 16 business units operating through its three divisions: Aerospace & Infrastructure; Communications & Security and Maritime & Land.

Aerospace & Infrastructure

  • Energy (comprising Nuclear Control Systems* and Nuclear Sensors & Process Instrumentation)
  • Precision Control Systems*

Communications & Security

  • 3eTI
  • Advanced Tactical Systems
  • Communications & Integrated Systems*
  • Forensic Technology
  • Herley
  • TCS

Maritime & Land

  • Avalon Systems
  • Command and Sonar Systems*
  • EMS Development Corporation
  • Flightline Systems
  • Maritime Systems
  • Ocean Systems
  • PMES*
  • USSI

* trading names for Ultra Electronics Limited

We provide a wide range of specialist capabilities in the Defence & Aerospace, Security & Cyber and Transport and Energy Markets. Ultra’s core markets are in North America, the UK and Australia, however we will continue to develop strategic positions where there is strong growth potential.


Our supply chains

Each of our business units operate autonomously and have responsibility for management of their own supply chain. Policy and guidance is provided centrally from Head office and via the Ultra Procurement Council.

Ultra is committed to ensuring there is transparency in its business and in its approach to tackling modern slavery throughout its supply chains. To this end, modern Slavery is a regularly discussed at the Procurement Council meetings.

The Procurement Council has determined that, in general, Ultra has a low dependency on goods and services from suppliers that present a high modern slavery risk. The goods and services procured by our businesses tend to be Commercial Off the Shelf (COTS) products, high-end technology or consultancy / professional services from within North America, the UK, Australia or other low risk territories.

The following steps have been introduced by the Procurement Council to prevent modern slavery occurring within Ultra’s supply chains in the future:

  1. Determining and maintaining acceptable procedures for supplier pre-qualification;
  2. Ongoing assessment of modern slavery risks based on high country risks and high sector risks;
  3. Developing common local modern slavery policies;
  4. Providing a forum for discussing and recording modern slavery occurrences (if any) and preventing future occurrences;
  5. Developing and introducing training for relevant employees in Modern Slavery

 

Ultra expects the same high standards from all of its contractors, suppliers and other business partners and this is communicated:

  • In its commercial contracts with external organisations,
  • When adding/pre-qualifying suppliers to its vendor base,
  • When conducting audits or visits at supplier sites.

 


Our policies on slavery and human trafficking

Business Managing Directors and Presidents are responsible for the implementation of local slavery and human trafficking policies within their respective businesses. Divisional MDs/Presidents are responsible for monitoring policy compliance by the businesses within their division.

Managing Directors and Presidents shall ensure that:

  • A written policy is maintained by their business which strictly prohibits: the use of modern slavery in their business or their supply chains; and their business does not support or engage suppliers where they are aware of modern slavery within the suppliers’ business or supply chains.
  • Their business has in place systems to: identify and assess potential risks of modern slavery in their business and their supply chains; mitigate the risk of modern slavery occurring in their business and supply chains; and monitor potential risk areas in their business and supply chains.
  • Terms and conditions of purchase forbidding the use of modern slavery practices are adopted by their business with the right to terminate a relationship with a supplier if issues of noncompliance are discovered and/or noncompliance is not addressed in a timely manner.

 

We have an independently managed confidential reporting line for employees and third parties to report any concerns in relation to modern slavery.


Training

Managing Directors and Presidents have responsibility for providing adequate and regular training to employees in their business to ensure a high level of understanding of the risks of modern slavery occurring in their business and supply chains.


Measuring effectiveness

The effectiveness of Ultra’s Modern Slavery policy is measured in the following ways:

  1. Business compliance with its local modern slavery policy;
  2. Rolling refresh of business risk assessments to ensure any changes in the profile of supply chain risks are considered, assessed and appropriately managed.
  3. Review of:
    1. the terms and conditions businesses have with their suppliers;
    2. the due diligence processes adopted by businesses; and
    3. the modern slavery training that has taken place in each business.
  4. Recording and monitoring modern slavery incidents (if any) within Ultra’s supply chains and, where necessary, developing corrective measures.

 

The Procurement Council provides oversight and challenge to this review process.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Ultra’s slavery and human trafficking statement for the financial year ending 31 December 2018.

The board of directors of Ultra Electronics Holdings plc. approved this statement at its board meeting dated 1 August 2019.

Simon Pryce
Chief Executive