MODERN SLAVERY STATEMENT
FY2022
This publication is the Modern Slavery Statement (‘Statement’) of Minova International Limited, incorporated and registered in England and Wales with company number 04373275 (‘Minova’) and its subsidiaries for the calendar and financial year ended 31 December 2022. This Statement is made pursuant to the U.K. Modern Slavery Act 2015 (‘Act’) and has been approved by the Minova Board of Directors (its Principal Governing body).
REPORTING ENTITY, STRUCTURE, OPERATIONS AND SUPPLY CHAIN
REPORTING ENTITY AND STRUCTURE
Minova is the ‘reporting entity’ covered by this Statement and the terms ‘Minova Group’, ‘Group’, ‘we’, ‘us’ and ‘our’ collectively refer to Minova and all the direct and indirect subsidiaries in which Minova held more than a fifty percent (50%) ownership interest during the reporting year, except where the context otherwise requires.
The Group is privately held by Aurelius Group and is governed by the Minova Board of Directors and the Minova Group Executive Team.
OPERATIONS
Headquartered in London, Minova Group is a global company developing, manufacturing and selling ground-control products and services (‘Ground Support Solutions’) to a range of clients principally in the mining, construction and civil tunnelling industrial sectors around the world. Minova Group has 13 production sites and 18 sales offices across North America, Europe & the CIS, South Africa, India and Australia and more than 1,000 employees.
Our Ground Support Solutions include the design, engineering, manufacturing and finishing of specialised products and the distribution and installation of products that have been manufactured and/or procured (and / or whose components have been manufactured or procured) in many different countries around the world.
SUPPLY CHAIN
Our supply chain includes providers of finished products for distribution, together with providers of component parts, raw, semi-finished and finished materials and consumables for the Ground Support Solutions products we procure or manufacture to market, distribute and sell. Our suppliers are located in the U.K. and many foreign countries.
Our supply chain also includes the suppliers of products and services that would typically be required by any office, warehouse, workshop and manufacturing operations.
OUR POLICIES IN RELATION TO MODERN SLAVERY
We strongly value and support fundamental human rights and the prevention of modern slavery and human trafficking (collectively, ‘Modern Slavery’) in our supply chain and in all other aspects of our business operations.
Until part-way through 2022, the Minova Group were controlled subsidiaries of the Orica Limited Group (Australia) and, in accordance with agreed business transition arrangements, Orica’s Code of Conduct and Modern Slavery arrangements remained in effect for Minova throughout the entire 2022 reporting year and until the end of February 2023 and Minova adhered to the Orica Group policies and procedures during such period, which included the entire 2022 calendar year and annual reporting period for Minova under the Act. Notwithstanding the foregoing, Minova did post a separate annual statement under the Act on its own website for the 2021 reporting period.
As this is our first Modern Slavery Statement under the Act as a private, “stand-alone” company, we are still just taking the first steps in what we understand will be an ongoing journey towards getting greater transparency into and a better understanding of our supply chain and ensuring there is no Modern Slavery in our supply chain or other business operations. We are committed to making continuous ongoing improvement in our assessment and management of risk in this area.
ACTIONS TAKEN AND TO BE TAKEN IN RELATION TO MODERN SLAVERY AND HUMAN TRAFFICKING
We are not aware of any instances of Modern Slavery in our operations or supply chain. However, we have taken as a starting position that some risk likely assists and should be more fully assessed and, as applicable, addressed going forward given that:
(a) some of our supply chain does extend into countries that do not currently or historically have any Modern Slavery prevention legislation or culture or may otherwise have been deemed by reputable non-governmental organizations as having higher levels of Modern Slavery risk;
(b) we still have only limited visibility into the business and labour practices of some of our first-tier suppliers; and
(c) we have very limited visibility into the second-tier suppliers within our supply chain and beyond.
Some of the actions we have taken during 2022 financial / reporting year include:
In the 2023 financial year we plan to take additional steps to better understand where Modern Slavery risks are likely the highest within our supply chain; better assess such risks; determine what steps we can take to better mitigate such risks; and start implementing them.
Some our objectives in this area for the 2023 financial year include:
Given the global nature of our business and the breadth of our supply chain, we recognize the reality that ensuring that Modern Slavery is not taking place anywhere in our supply chain, and especially at tiers beyond our direct suppliers, will likely remain a significant challenge for the foreseeable future. It is our intention to develop and implement a risk-based approach and we are committed to achieving continuous improvement through such approach.
APPROVAL OF STATEMENT
The Board of Directors of Minova has unanimously approved this Statement and authorised Ryan Kerr, CEO, as the responsible executive of Minova to sign this Statement in accordance with the Act. The Minova Group is committed to the spirit and intent of the Modern Slavery Act.
Ryan Kerr
Chief Executive Officer
June 2023