Modern Slavey Policy Statement

This document was approved by Dwilde Consultancy as followed:

Executive From Date: 31/01/2022

Approver: David Wilde - Director 

Unless there are legislative or regulatory changes in the interim, this policy will be reviewed every two years. Should no substantive changes be required at that point, the policy will move to the next review cycle.

1.1 INTRODUCTION 

Dwilde Consulting has a zero-tolerance approach to slavery and is committed to preventing acts of slavery and human trafficking from occurring within our business and we expect the same high standards of our subcontractors. 

We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them. To ensure all our staff and sub-contractors, comply with our values, we require them to contractually commit to compliance with this Policy. 

1.2 OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING 

We are committed to ensuring that there is no modern slavery or human trafficking in our business. This Anti-slavery Statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business or our subcontractors. 

Our recruitment processes are both transparent and thorough. We have robust procedures in place for vetting new employees and ensuring we are able to accurately confirm their identities. 

We require that all employees, including those permanently employed, temporary agency staff, retained consultants and business associates read, understand and comply with this Policy. 

The prevention, detection and reporting of modern slavery in any part of our business or subcontractors is the responsibility of all those working for us or under our control. All staff are required to avoid any activity that might lead to, or suggest, a breach of this Policy. 

We all have a responsibility to help detect, prevent and report slavery and human trafficking, so we encourage to raise concerns about any issue or suspicion of modern slavery in any parts of our business, at the earliest possible stage. 

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 any of our subcontractors. 

Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. 

1.3 SUBCONTRACTORS ADHERENCE TO OUR VALUES 

Since the enactment of the Act we have taken steps to seek to ensure that any new agreements with suppliers include an express obligation for suppliers to comply with the Act, to implement due diligence procedures within its own supply chains and notify us in the event of any actual or potential incidence of modern slavery. 

In the event of a breach of these provisions, we will seek to resolve any issues with suppliers, and it may also seek to terminate the relationship with the supplier where a resolution is not achieved. This provision is regularly reviewed, and relevant amendments made. 

1.4 DUE DILIGENCE 

As part of Dwilde Consulting on-going commitment to comply with the Modern Slavery Act, 2015, Dwilde Consulting will both continue to monitor and mitigate any risks within Dwilde Consulting and our subcontractors, so that effective controls and contingency plans can be put in place if required. 

We have in place systems to: 

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our sub-contractors.
• Monitor potential risk areas in our supply chains. 

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. 

The Company’s due diligence process includes: 

• Building long-standing relationships with our sub-contractors.
• Making clear our expectations of business partners.
• Evaluating the modern slavery and human trafficking risks of each new sub-contractor. 

The success of this policy is dependent upon all employees and subcontractors playing an important part in helping to detect and eradicate slavery. As such, all individuals are encouraged to report any suspected slavery. 

1.5 TRAINING 

To ensure a high level of understanding of the Modern Slavery Act 2015 and the risks in our business and our subcontractors, we intend to roll out training to all relevant members of staff. 

1.6 FURTHER STEPS 

Dwilde Consulting is committed to combating slavery and human trafficking. As such, we will continue to review the processes that we have in place and improve them regularly. We also will require our subcontractors to provide training to their staff. 

1.7 Authorized and Reviewed

WE monitor this policy statement annually and this includes monitoring the following KPIs over the next financial year to measure how effective the processes have been: 

1. The number of employees who have received training on modern slavery risks. 
2. The number of suppliers we have carried out a risk assessment on their Modern Slavery policy.
3. Incidents reported.