2Excel (Holdings) Ltd Statement on Modern Slavery
This Modern Slavery Statement (“Statement”) is made pursuant to section 54 of the Modern Slavery Act 2015 (the “Act) and sets outs the steps taken by 2Excel (Holdings) Ltd and its subsidiaries (collectively “2Excel” or “we”) during the financial year ending March 2022 with the aim of ensuring there is no Modern Slavery in our business or our supply chain. This Statement forms part of our commitment to acting ethically in our business relationships.
Modern Slavery is used as an umbrella term for all offences of slavery, servitude, forced or compulsory labour and human trafficking.
The Act obliges us to state the steps we have taken during the financial year to reduce the risk of Modern Slavery taking place in any part of our business or supply chain. In accordance with section 54 of the Act, our Statement is structured under the following headings:
- Organisation and Supply Chain Structure
- Policies
- Due Diligence Process
- Risk Assessment
- Key Performance Indicators
- Training
1. Organisation and Supply Chain Structure
2Excel (Holdings) Ltd is a holding company for the 2Excel Aviation Ltd Group of companies. We are 51% employee owned and during the financial year ending March 2022 employed 243 staff. We are an aerospace services company split into 4 main revenue generating areas:
- Capability Development gets our customers’ and our own ideas airborne safely, compliantly, usefully, quickly, affordably and sustainably.
- Special Missions provides cutting-edge contract air services including market leading aerial dispersant services globally and, nationally, Search and Rescue, surveillance and on scene control.
- Charter provides impeccable air travel in Britain, Europe and beyond and keeps Support at readiness for Special Missions’ availability contracts.
- Exploit turns remotely sensed data into actionable insight to address real world challenges at national scale.
These are underpinned by our Support functions (Finance, HR, Communications, Commercial and business support, Operations, Training, Compliance, Safety, Security, Continuing Airworthiness Management and engineering support services). In addition, we operate an aerobatic display team, the Blades, who provide hospitality and entertainment options for corporate clients and private flyers.
We are a UK-based company but some of our services may be delivered in, from or to other countries, for example when we carry out a Charter or Special Missions flight. Our supply chain is wide ranging including, but not limited to, infrastructure, maintenance, aircraft parts, flight support services, utilities, office stationery and IT. Our supply chain is mainly based in the UK for services and the USA for aircraft parts but, other countries feature on an infrequent basis. Our supply chain can be complex where specific aircraft parts are required and may result in us buying low-value items infrequently from many different suppliers.
2. Policies
Through our existing Sustainability Policy and its subordinate policies and plans we are committed to assessing, preventing and mitigating the risk of modern slavery. These include, but are not restricted to, our Social Value Policy, Grievance Policy and various ways of working documents that detail how we should select businesses within our supply chain. Furthermore, employees are encouraged to raise concerns or suspicions on slavery or human trafficking to a supervisor, manager, Director or the HR Department at any time.
In financial year 2022-23 we intend to introduce a Whistleblowing Policy and a Code of Conduct (Ethics) document which will further strengthen our controls related to modern slavery. We are considering bolstering our procurement processes with a dedicated procurement specialist and a dedicated Procurement Policy.
3. Due Diligence Process
We ensure due diligence is carried out when hiring any employee to minimise the risk of modern slavery in our business. This is done through the Baseline Personnel Security Standard (BPSS) check for all new joiners which allows us to satisfy ourselves about the identity of the individual. In addition, all our roles are paid at least the National Minimum Wage.
We also assure our supply chain through regular auditing by our Compliance Monitoring team, in line with aviation regulatory requirements. During the financial year 2022-23 we aim to introduce specific modern slavery elements as part of our supplier auditing process to further strengthen our due diligence processes.
In addition, for any supplier where we spend, or are likely to spend, more than £100,000 in the financial year, or where we determine it necessary through our internal risk assessment, we shall require the supplier to provide a commitment that they will take appropriate steps to prevent modern slavery within their own business and supply chains. Where we have a choice of supplier, we will not use suppliers who fail to provide this commitment.
We are pleased to report that we have not been made aware of any allegations of Modern Slavery against any of our suppliers in financial year 2021-22. If we were to be, we would act to investigate any relationship with the supplier as soon as reasonably practical and report to the relevant authorities as appropriate.
4. Risk Assessment
Aviation is a low-risk industry sector regarding modern slavery. Nevertheless, we are committed to taking necessary steps to reduce the risk of modern slavery taking place in our business or at any visible level in our supply chain.
A Modern Slavery Risk Assessment will be introduced during financial year 2022-23. We will seek to use our aviation industry associations to share best practice and generate further ideas.
5. Key Performance Indicators
2Excel have assessed their current KPIs and do not believe they indirectly or directly increase or influence the modern slavery risk that the Group carries.
2Excel will consider introducing Modern Slavery KPI(s) during the financial year 2022-23 which may include:
- The number of employees who have undertaken training (percentage of total employees);
- The number of suppliers, where our spend in financial year exceeds £100,000 or where deemed necessary by our internal risk assessment, audited for Modern Slavery processes;
- The number of suppliers used who have agreed to comply completely with our commitment to prevent Modern Slavery (percentage of total suppliers).
6. Training
2Excel introduced Modern Slavery Training via a third-party online e-learning platform in September 2020. The training raised awareness of modern slavery, including how to identify victims and how to report. Due to the provider being sold, the training was no longer made available to us in the Financial Year 2021/22. In April 2022, we introduced a new e-learning provider and restarted annual Modern Slavery training for all staff from July 2022.
Where required and appropriate, more in depth and/or specific training can be sourced for individual employees or functions that have that need.
7. Updates and Approval
This Modern Slavery Statement will be reviewed annually and updated as necessary.
This Statement has been endorsed by the 2Excel Board, 2Excel Management Board and the Environmental, Social Value and Governance (ESG) Steering Group.
This Modern Slavery Statement has been approved and authorised by: Louise Campbell, Board Director, 15th August 2022
