Annual Modern Slavery Statement for the HSS Group1 introduction

It continues to be a priority for HSS Hire Group plc to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain. We maintain a zero tolerance approach against any form of slavery or human trafficking throughout our business or in our supply chains. This statement sets out the steps we have taken in our organisation and supply chain to identify and prevent the risk of modern slavery and monitor compliance by our suppliers during the 2023 financial year.

Our business

We are a market leader in equipment hire and related services in the UK and Ireland. We offer a one-stop shop for all equipment hire through the complementary combination of our HSS ProService and HSS Operations divisions. HSS ProService is a capital-light, scalable, technology-based business focussing on sales acquisition, whilst HSS Operations is a fleet owning fulfilment business focussing on customer service, health and safety and efficiency. Our vision is to become the market-leading, digitally-led brand for equipment services. We build on the sustainable nature of our business model with an equally responsible approach to how we conduct our business activities, both inside and outside of our organisation. For further information on our business, please visit https://www.hsshiregroup.com/.

Our supply chains

We procure hire equipment and building materials from over 900 supply chain partners across the UK and Ireland.

Our policy on slavery and human trafficking

We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We regularly review and update our policies. Our Anti-Slavery and Human Trafficking Policy is communicated to all staff and reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. We also have a Code of Ethics which cross-refers to our Anti-Slavery and Human Trafficking Policy and other policies available here. Our Whistleblowing Policy encourages staff to report any concerns they may have, including matters like modern slavery.

We have a Supplier Ethics & Conduct Policy which sets out the practices and policies we expect all our suppliers to adhere to here. Our Board of Directors has overall responsibility for ensuring compliance with this policy and management at all levels ensure those reporting to them understand and comply with this policy on an ongoing basis.

Our supply chains and due diligence processes

We carry out robust due diligence and audits on our supply chain to ensure modern slavery is not taking place. As part of our due diligence and modern slavery prevention steps, we ask all our suppliers to complete a mandatory onboarding questionnaire to assess the risk in their businesses and to confirm they have a Modern Slavery Policy in place. Additionally, each supplier must agree to adhere to our Supplier Ethics & Conduct Policy prior to becoming a supplier. We adopt a robust approach and do not onboard suppliers who do not meet our internal accreditation standards. Our policy is available at: https://www.hss.com/medias/sys_master/docs/docs/9107076186142.pdf. We also maintain regular communication with our supply chain to ensure any weaknesses are identified, escalated and resolved. These activities continued during FY23. We utilise a supplier portal and internal database which facilitates our review of suppliers’ policies and procedures before they are on-boarded into our supply chain to ensure that our ethics and zero tolerance approach towards modern slavery and human trafficking are aligned with our suppliers. To ensure transparency, we conduct annual mandatory audits on our re-hire suppliers. In this audit we ask suppliers to provide details of their human rights policies, including their antislavery & human trafficking policy. No evidence of modern slavery or human trafficking was identified in our supply chain during 2023.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, we maintain an e-learning training programme for staff. This mandatory training is designed to ensure that staff are aware of the signs of modern slavery and what to do if they suspect any practices exist.

Contractual terms

The sets of terms and conditions used in the Group include a requirement to comply with law (including the Modern Slavery Act 2015), maintain and uphold similar policies and allow us the right to audit and terminate contracts for non-compliance. We have continued to see many of our customers include obligations in their standard contracts for suppliers such as HSS to maintain Modern Slavery policies and ethical business practices at least as stringent as theirs, which reflects the approach we take with our own suppliers.

Further steps

During FY24 we will: • continue to raise awareness by ensuring all new colleagues complete the mandatory training modules relating to modern slavery and human trafficking; • continue supplier due diligence, with annual reviews and spot checks focusing on measuring risk and effectiveness; • continue to perform mandatory annual audits on all our re-hire suppliers; • continue to review our internal Anti-Slavery and Human Trafficking Policy provided to colleagues and our external Code of Ethics; • continue to review our Supplier Ethics & Conduct Policy that includes additional ESG elements, enhanced minimum standards, benchmarks and supplier auditing processes. This policy shall also contractually oblige the suppliers to perform to our standards. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's Modern Slavery statement for the financial year ending 30 December 2023, which was approved by the HSS Board of Directors on 26 June 2024.

Alan Peterson,
Chairman

26 June 2024