Modern Slavery Policy

1. General Statement

1.1 This policy governs the required level of awareness and commitment that Dekco expects you to have in order to assist the company in ensuring it does all it can to remove any form of human trafficking and modern slavery from its supply chains and overall business. 

1.2 All employees, internal contractors and suppliers and business partners, must fully comply with this policy.

2. Policy statement 

2.1 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 our supply chain.

2.2 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, 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 we expect that our suppliers will hold their own suppliers to the same high standards. 

2.3 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.

3. Responsibility for the policy 

3.1 Dekco 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. 

3.2 The HR Business Partner 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 slavery.

3.3 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.

4. Compliance with the policy

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

4.2 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. 

4.3 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chain 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 immediately. If the matter is extremely serious then you should notify a director. 

4.5 You may also contact the Suspicious Activity Confidential Feedback Line on 0800 012 1700 (see https://www.modernslaveryhelpline.org/report). This helpline may be accessed by any person wishing to raise a concern and all reports are kept in confidence. 

4.6 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 chain constitutes any of the various forms of modern slavery, raise it with your manager or through the confidential helpline. 

4.7 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 our supply chain. 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 HR Business Partner immediately. If the matter is not remedied, and you are an employee you should raise it formally using our Grievance Procedure.

5. Communication and awareness of this policy

5.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chain, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary. 

5.2 Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. 

6. Breaches of this policy 

6.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

6.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

7. Review of this policy

7.1 This policy will be reviewed by the Board of Directors on a regular basis (at least annually) and may be amended from time to time