Modern Slavery Policy

Background

The Modern Day Slavery Act came into force in the UK in October 2015

There are an estimated 30 million people enslaved today, 68% are subject to forced labour. The International Labour Organisation (ILO) estimates that the profit generated by forced labour is USD150 Billion annually.

The act consolidates slavery and trafficking offences and introduces tougher penalties and sentencing rules. The changes ensure that the National Crime Agency, the Police and other Law Enforcement agencies have the power to pursue, disrupt and bring to justice those engaged in human trafficking and slavery, servitude and forced or compulsory labour. It also introduces measures to enhance the protection of victims of slavery and trafficking.

Denby Holdings Ltd has a zero tolerance to slavery and human trafficking and is committed to legal compliance with the Modern Slavery Act, it’s ethical standards and fundamental Human Rights.

The rules set out in this Policy apply not only to the Company’s direct employees but also to the Company Suppliers, Sub-Contractors and other Business Partners.

Rules of Engagement

· Denby Holdings Ltd prohibits any indirect benefiting from or contributing to Modern Slavery

· Denby Holdings Ltd will not knowingly benefit in any way from forced or involuntary labour, whether in the form of prison labour, indentured labour, bonded labour or otherwise. All work must be voluntary and workers have the freedom to terminate their employment, having completed an agreed notice period, without penalty.

· Denby Holdings Ltd will not knowingly work with any Supplier, Subcontractor or Service Provider who charges workers recruitment fees. Workers should not be charged any fees or costs for recruitment, directly or indirectly.

· Denby Holdings Ltd will not knowingly work with Suppliers, Subcontractors or Service Providers who retain worker’s identity documentation or other valuable items, including work permits or travel documents (passports).

· Denby Holdings Ltd will not knowingly work with Suppliers, Subcontractors or Service Providers who require workers to lodge deposits or bonds.

· Denby Holdings Ltd will not knowingly work with suppliers who do not provide written contracts of employment detailing the employee rights and responsibilities, working hours, salary and other relevant employment conditions.

· Denby Holdings Ltd will not knowingly work with Suppliers, Subcontractors or Service Providers who carry out “Contract Substitution” (where the contract with the employee does not match the contract the worker signed with the agent in the home county or country.

· Any Supplier, Subcontractor or Service Provider to Denby Holdings Ltd must include provision of grievance mechanisms within their organisations in order that workers have a confidential and safe process for raising any concerns.

· Denby Holdings Ltd does not condone the use of any harsh or inhumane treatment. Disciplinary policies and procedures must be clearly defined and communicated to all workers and shall not include any corporal punishment, physical coercion or verbal abuse.

· Denby Holdings Ltd actively promotes equality in the workplace, irrespective of nationality or legal status. All Suppliers, Subcontractors or Services Providers to Denby Holdings must ensure that workers are paid at least the minimum wage required by applicable laws and workers shall not be forced to work in excess of the number of hours permitted by national law. All overtime must be voluntary unless contractually agreed and recompensed.

· Any supplier, Subcontractor or Service Provider to Denby Holdings Ltd should ensure workers have freedom of movement. Workers should not be physically confined to Factory premises. Mandatory residence in employer operated facilities shall not be made a condition of employment.

All Suppliers, Sub-Contractors and Service Providers are required to adopt the labour policies within their own Code of Conduct as outlined above and be able to demonstrate that concrete steps have been undertaken to implement these labour policies.

Denby Holdings Ltd reserves the right to request compliance-related information and to carry out audits at any time having given reasonable notice.

Following an audit, any instances of non-compliance with the labour policies will be communicated via an audit report and corrective measures will be highlighted. Failure to comply with the corrective actions within a reasonable timeframe will result in the cancellation of orders and termination of contracts.