Anti-Slavery and Human Trafficking Policy December 2018
1. POLICY STATEMENT
1.1 This statement is made pursuant to section 54 of the Modern Slavery Act 2015, and sets out the steps that DCS has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
1.2 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
1.3 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
1.4 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
1.5 This policy does not form part of any employee’s contract of employment and we may amend it at any time.
2. RESPONSIBILITY FOR THE POLICY
2.1 The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
2.2 The compliance manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
2.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
2.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the compliance manager.
3. COMPLIANCE WITH THE POLICY
3.1 You must ensure that you read, understand and comply with this policy.
3.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
3.3 You must notify the compliance manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
3.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
3.5 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager as soon as possible. You should note that where appropriate, and with the welfare and safety of local workers as a priority, we may give support and guidance to our suppliers to help them address coercive or exploitative work practices in their own business and supply chains.
3.6 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or the compliance manager.
3.7 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.
4. OUR POLICIES
4.1 In addition to this anti-slavery policy, we operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees, to safeguard against human trafficking or individuals being forced to work against their will.
4.2 We operate a whistleblowing policy, so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisal.
5. OUR HIGH RISK AREAS
5.1 We have identified as a potential high-risk area that we recruit foreign temporary labour through employment agencies. We require our suppliers in this area to be vigilant so as to ensure that no staff offered to us are the victims of modern slavery or human trafficking. In particular, we ask them to ensure that where employees are living at the same address, they are not having their salaries paid into the same bank account as another worker.
6.1 DCS operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that a prospective supplier has never been convicted of offences relating to modern slavery and on-site audits, which include a review of working conditions where applicable. Our anti-slavery policy forms part of our contracts with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.
6.2 In addition, as part of our contract with suppliers, we require them to confirm to us specifically that:
6.2.1 they have taken steps to eradicate modern slavery within their own business;
6.2.2 they hold their own suppliers to account over modern slavery;
6.2.3 (for UK-based suppliers), they pay their employees at least the national minimum wage/the national living wage (as appropriate);
6.2.4 (for international suppliers), they pay their employees. Any prevailing minimum wage applicable within their country of operation;
7. COMMUNICATION AND AWARENESS OF THIS POLICY
7.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary, and in particular for employees in our procurement/buying teams, so that the understand signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.
7.2 Our commitment to addressing the issue of modern slavery in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
8. BREACHES OF THIS POLICY
8.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
8.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
9. APPROVAL OF THIS POLICY
9.1 This policy statement was approved by the Board of Directors on 18th December 2018. It will be subject to regular review.