Anti Slavery Statement
Last Reviewed: April 22nd 2023
Next Review: April 22nd 2024
Policy Statement
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 dealing and relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. We expect the same high standards from all of our contractors, suppliers and other business partners. 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 and we expect that our suppliers will hold their own suppliers to other same high standards.
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, agents, contractors, external consultants, third-party representatives and baseness partners.
This policy does not form part of any employee’s contract of employment and we may amend it at any time.
Scope
This policy applies to all employees, contractors, suppliers, and business partners of DVT. It covers all aspects of our operations, including:
- the organisation’s structure, its business and its supply chains
- the policies in relation to slavery and human trafficking
- the due diligence processes in relation to slavery and human trafficking in its business and supply chains
- the parts of business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk
- the effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate
- the training and capacity building about slavery and human trafficking available to its staff
Responsibility for the Policy
The Operations Department has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Chief Operations Officer 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.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given any required training.
Compliance with the Policy
Corruption can include graft, bribery, facilitation payments, or other forms of improper business practice. It has the same attributes as set out under Bribery above. It can be summarised as the misuse of entrusted power of office, whether in the public or private sector, for private gain.
Reporting Bribery and Corruption
You must ensure that you read, understand, and comply with this policy. The prevention, detection, and reporting of modern slavery in any part of our business or supply chain 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.
You must notify your manager or the COO as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
You are encouraged to raise concerns about any issue of suspicion of modern slavery in any parts of our business or the supply chains of any supplier tier at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible. 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 chain constitutes any of the various forms of modern slavery, raise it with the Procurement Department.
We aim to encourage openness and will support nay one 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 part of our supply chain. If you believe that you have suffered any such treatment, you should inform your manager immediately.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we conduct training to relevant members of our supply chain on the benefits they are entitled to as well as on anti-sexual harassment policies. We also require our suppliers of people to provide training to their employees on their rights, including relating to wages, benefits and grievance redressal forums.
We have also circulated a training module to create awareness on modern slavery and human trafficking to our employees who manage the supply chain.
Communication and Awareness of thePolicy
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at outset of our business relationship with them and reinforced as appropriate thereafter.
Continuous Improvement
We will regularly review and update this anti-slavery policy to ensure its effectiveness and relevance, adapting to changing circumstances and best practices.
Breaches of this Policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.