The Modern Slavery Act 2015 Modern Slavery and Human Trafficking Statement 2025

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes Hayakawa Densen Kogyo Co. Ltd.’s slavery and human trafficking statement. This report covers the company’s financial year to end December 2024.

1. Organisational structure and supply chains

Hayakawa Densen Kogyo Co. Ltd. (HDK Group) is a Japanese-based global manufacturer and supplier of wire harnesses, cable assemblies and components for the automotive, robotics, industrial, home appliance, lighting and other industries. The group consists of factories and offices operating in 10 countries across Europe, Asia and the North America.

Hayakawa International (UK) Ltd. (Hayakawa UK) is a subsidiary of HDK Group and operates from premises located at 5 Davy Way, Llay Industrial Estate, Wrexham, LL12 0PG, North Wales, United Kingdom.

HDK Group has an extensive global network of suppliers ranging from large multinational companies to small private limited companies.

2. Slavery and human trafficking policies

As a global business, HDK Group recognises its responsibility to uphold and protect the human rights of its employees and other individuals with whom the group deals throughout its supply chain and in its global operations.

HDK Group operates a zero-tolerance approach to slavery, forced labour and human trafficking and expects the same from its customers, suppliers, distributors, contractors and other suppliers of goods and services around the world.

All HDK Group employees operate to the corporate Code of Conduct

which includes the group’s core values and policies that ensure ethical business practice.

3. Supply chain due diligence

HDK Group aims to eliminate, as far as possible, the risk of modern slavery within its supply chain and to trade ethically and with integrity.

The continuing approach to managing potential modern slavery activities within its supply chain is to raise awareness of the issue through the means of audits, and to investigate any examples of areas of concern. This is done through both in-person audits and self-assessment audits which help to identify any supplier who could be classed as a potentially high risk. It is the aim of HDK Group to undertake the audit process on an annual basis.

In addition to this, HDK Group continues the use of self-assessment audits with lower risk suppliers, in which these suppliers are required to confirm that they work in agreement with the principles and values contained in HDK Group’s Supply Chain Code of Conduct.

Responses to audits and self-assessments are assessed in a fair and proportionate manner according to the level of risk associated with the relevant supplier and its products or services.

HDK Group employees who interact with the supply chains have received, and continue to receive, training on the risk of modern slavery, forced labour and human trafficking and are aware of HDK Group’s routes to escalate any identified concerns, without fear of repercussion.

HDK Group aims to conduct all aspects of its business in accordance with its core corporate values of integrity, respect and ethical business practices and HDK Group expects that all its suppliers will uphold these same values.

4. Identifying, assessing and managing risks

HDK Group are committed to implementing effective systems and controls to ensure that its suppliers of products and services acknowledge the Group’s standards for compliance with applicable laws and regulations, including those that relate to the prohibition of slavery, forced labour and human trafficking.

HDK Group believe that its exposure to the risks of modern-day slavery, forced labour and human trafficking is low within its own business and supply chain.

This assessment is under continuous review in order to determine if circumstances change that may require the HDK Group to take additional actions. The HDK Group work in collaboration with other industry leaders to ensure a process that optimises risk management, and requires all potential suppliers to demonstrate their capacity to meet the contractual requirements set out by the HDK Group. Furthermore, the HDK Group also look for clear demonstrations of commitment to corporate social responsibility and expect high standards of conduct from its suppliers and will not accept any behaviour contrary to its codes of conduct and policies.

5. Actions taken to address modern slavery

During the year under review, no identified instance of modern slavery, forced labour or human trafficking have been identified by the HDK Group across its supply chain.

Steps taken during the year include:

• A Supplier Code of Conduct which is readily available to all suppliers and customers of the Group, setting out the minimum standards and expectations in all areas of corporate ethic including modern slavery, health and safety, environment, data protection, anti-bribery and corruption, and whistle-blowing;
• Promotion of awareness relating to the provision of the Modern Slavery Act 2015 and the potential risks which may face the Group, through internal training and presentations to employees who are engaged in dealing with the supply chain;
• Ensuring that the Group’s recruitment policies, procedures and practices are appropriate to minimise the risk of modern slavery, forced labour and human trafficking.

• The HDK Group is also building on this work with the implementation of the supplier review procedures which include:

  • Conducting regular supplier due diligence by obtaining written declarations from suppliers which confirm that they are aware of the Modern Slavery Act and have taken, and will continue to take, positive steps to address the global issues of human trafficking, forced / bonded employment, servitude and compulsory labour.

Training and awareness

he HDK Group will continue to raise awareness of modern slavery, forced labour and human trafficking across its supply chain, and the clear principles are set out in the Supply Chain Code of Conduct which is freely available on the Hayakawa UK website.

Additional training and refresher courses are available for in-house training for HDK Group employees including Hayakawa UK, and all policies, procedures and codes of conduct are made freely available to employees, including the Whistle-Blowing policy and Equality & Diversity policy.

This statement has been approved by the Board of Directors, who will continue to review and update company policies and processes, and is signed on behalf of the Board by Devinder K Bansal, Director