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Modern Slavery Statement

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015.

Enhesa is a trusted partner to drive the transformation of compliance and sustainability.

We’re top solutions coming together as the leading provider of regulatory and sustainability intelligence worldwide. An integrated global business on a mission to make a difference – and to empower you to make our world a more sustainable place.

Enhesa Group N. V. (hereinafter, “Enhesa”) respects and promotes human rights, and through its business and operations, seeks to actively contribute to a more prosperous, equitable and fair society.

This statement covers the activities of the whole Enhesa Group, for the financial year running from January 2022 to December 2022 (partial update of 2023).

Our Organization’s Structure, Our Business, and Our Supply Chain

Enhesa Group comprises Enhesa N. V., which is the parent company of Enhesa Inc. in the US, Enhesa Kabushiki Kaisha in Japan, Enhesa (Shanghai) co. (China) Ltd., and CW Research Limited in England.

Enhesa Inc. has as subsidiaries Scivera LLC, Timberlake Ventures Inc., and Reg Scan LLC. Enhesa, N.V. has an office in Belgium and a branch in Portugal.

Enhesa group has grown since 2020 with the last acquisition in 2022.

Our core activities are providing intelligence to multinationals and enabling them to be compliant no matter how simple or complex their operations. We enable them with intelligence from the conception of a product, all the way through manufacturing, to the placing on the market until the final disposal and reuse.

For our clients, we are Enhesa Operations business including Reg Scan which is about providing clients with EHS regulatory intelligence. Chemical Watch by Enhesa is about enabling clients with product compliance and product stewardship insights. And Enhesa Sustainable Chemistry is about enabling clients to make safer and more sustainable choices for their products and process chemistry.

Enhesa’s supply chain is conformed by service suppliers and some goods suppliers. Specially subcontractors in the case of service suppliers.

Our Journey and Our Policies:

Since Enhesa as a group has become closer and more integrated, we have been identifying the actions and steps we need to take as a bigger group and not as the rather small companies we were in the past. 2022 was a year of integration and we have now a better understanding of our impacts and risks.

In 2022, the Enhesa ESG policy outlined our commitment to respect human rights. Our mission and values also reflect our commitment.

Towards the end of 2022, an important initiative regarding our ESG and Sustainability started within Enhesa. And in 2023, it was approved and took off. We issued the following policies related to respecting Human Rights and to prevent any modern slavery issue. Modern slavery understood as the recruitment, movement, harbouring or receiving of children, women or men through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation:

  • Human Rights Policy: applicable to all Enhesa Group and through its business operations. The policy is based on international instruments, such as the Guiding Principles for Business and Human Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework (UN) and the Forced Labor Convention (International Labor Organization – ILO)
  • Sustainability and ESG Policy: Which outlines our commitment to the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct
  • Sustainable Procurement Policy: Which enables buyers within the Enhesa Group to select suppliers which are aligned with our values and commitments such as respecting human rights, good labour practices, and not tolerating any form of modern slavery. This policy also provides the basis for buyers to conduct reasonable due diligence
  • Recruitment Policy: which respects human rights of candidates and also prohibits recruiting any person below the legal age to work
  • Whistleblowing procedure: which allows any employee and stakeholder of Enhesa group to raise concerns, such as human rights violations

Knowing Our Value Chain and the Most Vulnerable Parts Presenting Higher Risks and Enhesa’s response

Enhesa’s supply chain is conformed by service suppliers mainly subcontractors.

We understand that there are sectors and countries with a higher risk of exposure than those where we operate Belgium, Canada, China, Japan, Portugal, UK, and US. Even if we operate in countries and a sector with lower risk, according to the Global Slavery Index (https://www.walkfree.org/global-slavery-index/), we acknowledge we also have a part to play.

According to the Human Rights Guidance tool for investment, the services sector comprising professional services has a wide variety of risks. The main risks can include low wages and long hours; substantial use of migrant workers; trafficking of workers, especially women and children, who are then forced to work.

As part of our actions, we make use of different sources to understand the risks and be able to identify prevent, mitigate, and provide remedy where possible.

Enhesa has developed the Sustainable Procurement Practice Policy which enables buyers to conduct due diligence on suppliers by searching in the OECD database for any pending instance for failing to conduct responsible business conduct in accordance with the OECD Guidelines. We understand this is the beginning of a continuous improvement.

Our Performance Indicators and their Effectiveness

No case of modern slavery has been registered for 2022. For the coming years, we aim at collecting the number of suppliers that have controls in place and also to identify entities with already instances of human rights violations.

Next Steps

In the coming years, we are planning to:

  • provide training on human rights and modern slavery;
  • include clauses in our contracts across our value chain;
  • collecting the number of suppliers that have controls in place; and
  • strengthen our due diligence across our value chain.