This is in accordance with the terms of the 2015 Modern Slavery Act Section 54. This declaration, as provided by the Act, provides a detailed procedure to decrease the possibility of human trafficking and slavery in every aspect of Dynamo of London Limited’s industry. The previous statement relates to Dynamo of London.
Modern slavery is a horrible, appalling crime that deprives one’s freedom and self-respect for money. There are countless individuals around the world, including those in industrialised nations, who are both enslaved and abused. Any business is vulnerable to criminal activity in the supply chain and operational aspects.
In Dynamo of London, there being no tolerance for modern slavery, we are dedicated to the complete prevention of human trafficking in our distribution network. In view of our statement, we have set in motion a solid course of action to fight modern slavery.
We build a working partnership of confidence and honesty with both of our drivers and customers, which benefits everybody involved. The on-boarding process involves careful selection of drivers as well as verification of the reputation, respect for the protection of both their health and the workplace. As far as we know, our company/our clients/drivers have not been engaged in human trafficking, yet if we learned about such an individual’s violations, we will take urgent action.
We continue to make sure that our employees are aware of the Modern Slavery Act, of the definitions of slavery and human trafficking and that they know what to do should they suspect a case of slavery or human trafficking. To better support this, our employee induction and compliance training programme is being updated. Our Head of Procurement holds the Professional level of the CIPS Global Standard for Procurement and Supply qualification, and plans are in place to extend the CIPS qualification to the rest of the team.
In the past year, we conducted a risk assessment of our supply chain by taking into account:
- The risk profile of individual countries based on the Global Slavery Index
- The business services rendered by the suppliers
- The presence of vulnerable demographic groups
- A news analysis and the insights of labour and human rights groups
This assessment will determine our response and the risk controls that we implement.
Dynamo of London Limited operates the following policies for identifying and preventing slavery and human trafficking in our operations:
- Whistleblowing Policy – we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. We provide a confidential helpline to protect the identity of whistle-blowers.
- Code of Conduct – our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
- Purchasing Code – we have updated our Purchasing Code and supplier contracts to make explicit reference to slavery and human trafficking.
Supplier due diligence conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. This includes:
- Assessing risks in the provision of particular services
- Auditing the suppliers, and their health and safety standards, labour relations and employee contracts
- Requiring improvements to substandard employment practices
- Sanctioning suppliers that fail to improve their performance in line with our requirements
We require all suppliers to attest that:
- They don’t use any form of forced compulsory or slave labour
- Their employees work voluntarily and are entitled to leave work
- They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment
- They don’t require employees to post a deposit/bond and don’t withhold their salaries for any reasons
- They don’t require employees to surrender their passports or work permits as a condition of employment
Dynamo of London has raised awareness of modern slavery issues by putting up posters across our facilities and sending an email that is focused specifically on modern slavery to all our staff, which explains:
- Our commitment in the fight against modern slavery
- Red flags for potential cases of slavery or human trafficking
- How employees should report suspicions of modern slavery
In addition to the awareness programme, Dynamo of London will roll out a fresh e-learning course to all employees and supplier contacts, which covers:
- Various forms of modern slavery in which people can be held and exploited
- The size of the problem and the risk to our organisation
- How employees can identify the signs of slavery and human trafficking, including unrealistically low prices
- How employees should respond if they suspect slavery or human trafficking
- How suppliers can escalate potential slavery or human trafficking issues to the relevant people within their own organisation
- What external help is available for the victims of slavery
- What terms and guidance should be provided to suppliers in relation to slavery policies and controls
- What steps Dynamo of London Ltd will take if a supplier fails to implement anti-slavery policies or controls
- An attestation from employees that they will abide by Dynamo of London anti-slavery policy
Measuring how we’re performing
Dynamo of London Ltd has defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organisation and supply chain. These include:
- How many employees have completed mandatory training?
- How many suppliers have filled out our ethics questionnaire?
- How many suppliers have rolled out an awareness and training programme that is equivalent to ours?
- How many reports have been made by our employees that indicate their awareness of and sensitivity to ethical issues?
- What are the findings of our cross-functional Human Rights team, which reviews how we are addressing modern slavery and human trafficking?
This statement covers 10 March 2021 to 31 October 2022 and has been approved by the board of Dynamo of London Ltd at the board meeting on 01 March 2021.