Sonardyne Group Limited (the “Company”), formed in April 2020 and its wholly owned group companies, including Chelsea Technologies Limited, EIVA a/s, Sonardyne International Limited, and subsidiaries, Wavefront Systems Limited and 2G Robotics Inc. (together the “Sonardyne Group” or “Group”) have a zero-tolerance approach to any form of modern slavery and we are committed to acting in an ethical manner and with integrity and transparency in our business dealings.

The Company supports the provisions set out in the Modern Slavery Act 2015 (Act). This statement is made pursuant to section 54(1) of the Act and constitutes the Group’s slavery and human trafficking statement.

This statement outlines the steps taken by the Sonardyne Group in the financial year ending 31 March 2020 to ensure that slavery, any form of forced labour or human trafficking is not taking place within any part of our business or within our supply chains.

This year, one of our Group companies, Sonardyne International Limited, has met the criteria to report under the Act.

Our Organisation

The Sonardyne Group, formed in March 2020, has its head office in the United Kingdom and is a leading provider of marine and subsea solutions worldwide; operating in a wide range of sectors within the energy, science, defence, and commercial markets. We have 450 employees located in offices across 6 countries including the United Kingdom, Denmark, United States of America, Singapore, Brazil and Canada and an agent and reseller network worldwide. In 2020 the companies now forming Sonardyne Group had a combined annual turnover of over £50 million.

Policies

Within Sonardyne International Limited the Modern Slavery Policy, Code of Conduct, Ethics and Anti-Bribery Policy and Supplier Code of Conduct reflected the commitment to acting ethically and with integrity in all business relationships and to implementing and enforcing effective systems and controls to ensure as far as possible that slavery, any form of forced labour and human trafficking are not taking place within the company or within its supply chains. Policies are complemented by a compliance programme which includes training, risk assessments, audit assurance, monitoring and review processes.

Copies of our policies are available on the website, www.sonardyne.com.

 Due Diligence, Monitoring Risk and Ensuring Compliance

Sonardyne International Limited conducts a preliminary modern slavery risk assessment on all its suppliers as part of its New Supplier Approval process. This risk assessment is based upon geography, the nature of the supply and of the transaction. In 2020 the supplier due diligence questionnaire was updated, to include analysis of modern slavery risks and was issued to suppliers located in countries, or operating in markets, considered to be high risk. Sonardyne International Limited has operated a companywide whistleblowing process and all employees who have regular contacts with suppliers, including directors, have undertaken mandatory compliance training.

Compliance is central to all our operations across all group companies and we will continue to monitor compliance on an ongoing basis, through:

  • Identifying and mitigating potential risk areas in supply chains and third parties through risk assessment and due diligence.
  • Reviewing suppliers’ compliance with our Modern Slavery Policy, Supplier Code of Conduct, supplier pre-qualification procedures, Standard Terms and Conditions of Purchase, and other contractual terms. A copy of the Supplier Code of Conduct, which has been updated to include Modern Slavery obligations since the last statement, is provided to suppliers in order that they can confirm their compliance.
  • Monitoring potential risk areas in supply chains.
  • Reporting systems to encourage the reporting of concerns and the protection of whistle blowers.

Supported by our audit, legal and business teams, on-going compliance within the Group will be the responsibility of Group operating company Managing Directors who are required to monitor compliance and report to their local boards and to the Group Chief Executive Officer who has overall responsibility for compliance.

As a group of companies formed in 2020 this is a key area of focus and in order to support the group approach, we plan to co-ordinate a risk assessment of modern slavery across the Group. This will be supported by a group wide approach to ethical policies and guidelines including whistleblowing, code of conduct, code of ethics and Modern Slavery.

Following approval by the Company’s Board of Directors, our Modern Slavery Policy is being disseminated to all trading companies within the Sonardyne Group and each business is required to take steps to ensure that its staff and its suppliers are aware of the policy and that they understand and comply with it.

Training

We provide training to employees to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business. This training will be disseminated further across the Sonardyne Group during 2020/2021.

As Chief Executive Officer, I will continue to lead this important agenda for the Sonardyne Group and will report annually on the steps that we have taken and will be taking to prevent modern slavery.

A copy of this Statement is available on the Company’s website at www.sonardyne.group and also at the Modern Slavery Registry which is maintained by the Business & Human Rights Resource Centre.

This statement was approved by the Board of Directors of the Company and signed on its behalf by:

John Ramsden
Chief Executive Officer
Sonardyne Group Limited

November 2020