Modern Slavery Statement

Overview

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.

Dals has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in every business relationship, process, dealing or communication and will enforce effective systems and controls to ensure modern slavery is not taking place anywhere within our own business or in any of our supply chains.

Dals considers modern slavery to be;

• Human trafficking. The use of violence, threats or coercion to transport, recruit or harbour people in order to exploit them for purposes such as forced prostitution, labour, criminality, marriage or organ removal.
• Forced labour. Any work or services people are forced to do against their will under threat of punishment, for example through mental or physical threat.
• Debt bondage/bonded labour. The world’s most widespread form of slavery.

People trapped in poverty borrow money and are forced to work to pay off the debt, losing control over both their employment conditions and the debt.

• Slavery of children. When a child is exploited for someone else’s gain. This can include child trafficking, child soldiers, child marriage and child domestic slavery.
• Forced and early marriage. When someone is married against their will and cannot leave. Most child marriages can be considered slavery.
• Being physically constrained, or to have restriction placed upon an individual’s freedom of movement
• Being dehumanised, treated as a commodity or being bought and sold as property

Responsibility

This policy applies to all persons working for or on behalf of Dals in any capacity. This policy applied to persons at all levels, including, but not limited to board members, directors, officers, contractors, freelancers, consultants, third-party representatives and business partners.

Directors

The Director(s) hold overall accountability and authority for ensuring business compliance with the Modern Slavery Act 2015. They are responsible for ensuring that this policy complies with the relevant legal and ethical standards and for ensuring that anyone working for on behalf of Dals is given adequate and regular training on the issues of modern slavery, this policy and that they understand and abide by the regulation and this policy.

Risk & Compliance Manager

The Risk & Compliance Manager is also responsible for ensuring this policy complies with the relevant legal and ethical standards and for ensuring that anyone working for on behalf of Dals is given adequate and regular training on the issues of modern slavery, this policy and that they understand and abide by the regulation and this policy.

They also act as the first point of contact for any queries or concerns relating to this policy as well as being responsible for updating this policy.

Managers

Managers are expected to ensure that their teams are aware of, understand and abide by this policy. They are expected to monitor its use and effectiveness and ensure that their team operate in line with this policy.

Employees

Employees are expected to familiarise themselves with this policy and abide by it at all times. All employees are encouraged to report any concerns or suspicions of modern slavery within the business or supply chain to the Risk & Compliance Manager at the earliest possible stage. Employees should refer to our whistleblowing policy for more guidance.

Commitment

To ensure that Dals adhered to the Modern Slavery Act 2015 and acts ethically in terms of business practice, we commit that;

• No labour provided to Dals in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking
• We will not enter into business with any other organisation, whether in the United Kingdom or abroad, which knowingly supports or is found to involve itself in any form of modern slavery
• We will ensure that our zero-tolerance approach to modern slavery is communicated to any organisation or person at the outset of the business relationship with them
• We will conduct supplier due diligence and conduct regular audits to ensure that any suppliers operate in line with this policy & the Modern Slavery Act 2015
• An annual review of supplier contracts to identify and assess the potential risks in its supply chains. This includes power of contract termination in the event that the supplier is, or is suspected, to be involved in modern slavery.
• An annual assessment of our services concerning potential instances of slavery and reporting of actions taken to address the risk to modern slavery, all included in the Modern Slavery Statement
• We will regularly review our internal practices to ensure that they are robust & comply with the Modern Slavery Act 2015
• We will ensure that anyone working on behalf of Dals is given adequate and regular training on the issues of modern slavery & this policy
• We keep up to date with any changes to the Modern Slavery Act 2015 and act accordingly to ensure compliance

Non-Compliance with this Policy

Non-conformance with this policy may result in disciplinary action, as outlined in the Employee Handbook.