1. Background

Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers.  It can take on various forms, such as slavery, servitude, forced or compulsory labour and human trafficking.  The Company has a zero tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery or human trafficking are not taking place anywhere within either its own business of in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.

The Company also expects the same high standards from all of its suppliers, contractors and other business partners and as part of its contracting processes, it includes specific prohibitions against the use of modern slavery, and expects that its suppliers will in turn hold their own suppliers to the same standards.

This policy sets out how we intend to prevent, detect and deal with all cases of modern slavery.

2. Policy

Our approach is to proactively and effectively manage the risk of modern slavery and human trafficking by:

• Maintaining and updating policies in line with legislation and best practice
• Recruitment utilising our Recruitment Policy
• Working as a minimum to the National Minimum Wage
• Tracking, monitoring and preventing the risk of the occurrence through diligent management
• Audits where applicable of our supply chain
• Thorough supply chain due diligence
• Investigating thoroughly any issues/concerns detected
• Application of sanctions against those suppliers who do not conform to any legal requirements
• Provide any appropriate/relevant training and guidance to employees

Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways, however the Company accepts that it has a responsibility through its due diligence processes to ensure there are no concerns.

This policy applies to all individuals working for the Company or on the Company’s behalf in any capacity.

3. Procedure

The prevention, detection and reporting of modern slavery in any part of the Company’s business or supply chains is the responsibility of all those working for the Company or under the Company’s control.  You are required to avoid any activity that might lead to a breach of this policy.

If you believe or suspect a breach of or conflict with this policy has occurred or may occur, you must notify your line manager or to the Commercial Director.  You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the Company’s business or supply chains as soon as possible.  If you are unsure about whether a particular act, the treatment of workers or their working conditions within any of the Company’s supply chains constitutes any of the various forms of modern slavery, please raise it with your line manger or the Commercial Director.

DMN promotes openness and will support anyone who raises a genuine concern in good faith under this policy.  The company is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or many be taking place in any part of the business or in any of its supply chain.

Our policy will be communicated to all new and current Company employees and suppliers when entering into new or renewed contracts.

Any breach of this policy by any employee will result in disciplinary action which could result in dismissal for gross misconduct.

The company will terminate any commercial relationships with supplier if they are in breach of this policy and/or are found to have been involved in modern slavery.

4. Implementing the policy & prevention

The Company will be responsible for implementing this policy, ensuring that all staff members are aware of the policy by making it available to view on the Company shared drive/HR toolkit system as well as being included within the induction process.

5. Communication

We will communicate this policy and relevant guidance to employees across the Group through inductions, the HR toolkit system and policy updates. We will also communicate this policy to our suppliers, contractors and business partners.

6. Responsibilities

You must ensure you read, understand and comply with this policy.

The board of Directors have overall responsibility for implementing this policy.

Line Managers are responsible for ensuring that those reporting to them understand and comply with this policy.

7. Record-Keeping, monitoring and review

The Procurement and Commercial team will have the day to day responsibility for keeping all supplier related records on compliance of this policy and annual declarations.

Effective business audits and checks including the use of the company risk register and labour rate monitoring through the payroll system.

DMN Logistics Ltd will review the implementation of this policy annually in respect of its suitability, adequacy and effectiveness and make improvements as appropriate.

This policy will be monitored by the Directors of the Company and reviewed on an annual basis unless specific changes are needed before then. DMN Logistics Ltd is committed to making this policy work.