Modern Slavery and Human Trafficking Policy Statement

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.

Design One is committed to improving our practices to combat slavery and human trafficking. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement.

Design One is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

In view of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free we have put in place a designated Modern Slavery and Human Trafficking Policy.

Our Modern Slavery and Human Trafficking Policy demonstrate 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 supply chains.

Design One has 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 any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, 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 as part of our contracting processes, in the coming year we will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, agents, contractors, external consultants, third-party representatives and business partners.

Responsibility for the policy

Design One has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

Design One 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 modern slavery.

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 the subject and the issue of modern slavery in supply chains.

You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to The Directors.

Compliance with the policy

As part of our initiative to identify and mitigate risk we have in place:

Human Resource procedures

• A comprehensive range of policies and practices have been applied including an Equality and Diversity Statement, formal grievance and disciplinary policies to protect and ensure that employee rights and responsibilities are upheld.
• Regarding pay, Design One uses the National Living Wage rates, to safeguard and ensure that the hourly rate of employees does not fall below the current National Living Wage.

Procurement procedures

• Engage with our supplier base.
• Identify and monitor potential risk of slavery and human trafficking in our supply chains.
• Incorporate within our tender process to address slavery and human trafficking with potential new suppliers.

Supplier adherence to our values

Design One has a zero tolerance to slavery and human trafficking. To ensure all those in our supply chain (including contractors) comply with our values we have in place a supply chain compliance action list.

• Engage with supplier base to secure a commitment to work with Design One to identify and monitor slavery and human trafficking down the supply chain.
• Engage with potential new suppliers about commitment to Design One’s Modern Slavery and Human Trafficking Policy.

Raising awareness

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff, via Modern Slavery as a regular agenda item.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.

Our employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. Employees must notify their line manager OR a company Director as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future.

Our employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

If they believe or suspect a breach of this policy has occurred or that it may occur, they must notify their line manager or company Director OR report it in accordance with our Whistleblowing Policy as soon as possible.

If one of our employees is unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, they must raise their concerns with their line manager or company Director.

Design One 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. 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 supply chains.

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

If an employee believes that they have suffered any such treatment, they should inform their line manager immediately. If the matter is not remedied, the matter should be raised formally using our Grievance Procedure, which can be found in the current employee handbook.

Communication and awareness of this policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and updates will be provided using established methods of communication between the business and you.

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

Breaches of this policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.