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Anti-Slavery and Human Trafficking Policy

Whilst we are not legally obliged to have an anti-slavery policy, it is a subject that is morally important to us and as such we wish to express and publish our policy on this matter.

Modern slavery is a crime resulting in an abuse of the human rights of vulnerable workers. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking.

DNA has a zero tolerance approach to modern slavery and is committed to acting ethically with integrity and transparency in all of its business dealings and relationships. This is achieved by implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.

DNA 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.

Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, the Company accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.

This policy applies to all individuals working for DNA or on DNA’s behalf in any capacity, including employees, directors, agency workers, volunteers, agents, contractors, consultants and business partners.

Responsibility for the policy

The directors have an overall responsibility for ensuring that this policy complies with the Company’s legal and ethical obligations.

The Anti-Slavery & Human Tracking Officer has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible for investigating allegations of modern slavery in the Company’s business or supply chains.

 

Compliance

The prevention, detection and reporting of modern slavery in any part of DNA’s business or supply chains, whether in the UK or abroad, is the responsibility of all those working for DNA or under DNA’s control. DNA are required to avoid any activity that might lead to a breach of this policy.  If we believe or suspect a breach of or conflict with this policy has occurred or may occur, we will deal with the matter in accordance with our compliance code. DNA aims 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. DNA 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 may be taking place in any part of its business or in any of its supply chains.

 

Breach of the policy

Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct. The Company may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.

 

This document was last updated on 24th February, 2017

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