MODERN SLAVERY POLICY

This policy is applicable across the entire Dale Farm Group covering all business units, operating sites and supply chains. The aim of this policy is to eradicate all acts of modern slavery from our own business and from within our supply chain.


POLICY

The Company acknowledges responsibility under the Modern Slavery Act 2015 and will ensure transparency within the Company and with suppliers of goods and services to the Company. Dale Farm commits to developing and adopting a proactive approach to tackling hidden labour exploitation.

The policy encompasses all acts of:

The Company shall ensure adherence and compliance with legislation, policies and practices through due diligence and the auditing process.


POLICY COMMITMENTS:

a. Will develop and operate company procedures relevant to this issue.

b. Not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee.

c. Ensure that all staff responsible for directly recruiting staff are aware of issues around third-party labour exploitation and signs to look for and have signed appropriate Compliance Principles.

d. Ensure that labour sourcing and recruitment processes are under the control of trusted and competent staff members.

e. Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Licensing Authority and local police.

f. Provide information on tackling “Hidden Labour Exploitation” to our employees through workplace posters, worker leaflets and Induction training.

g. Encourage workers to report cases of hidden third-party labour exploitation, provide the means to do so and investigate and act on reports appropriately.

h. Positively encourage and support employees and agency workers to report such exploitation which may be occurring within their communities.

i. Positively encourage and support employees and agency workers to report such exploitation which may be occurring within their communities.

j. Require labour providers and other organisations in the labour supply chain to adopt policies and procedures consistent with the above.

Red Flag alerts include:

Red Flag alerts include:


WAGE PAYMENTS AND HOURS OF WORK

Workers will not be forced or coerced to work overtime above the limits permitted in national law and collective agreements. All overtime working is voluntary.

Wages are paid regularly (either weekly or monthly) and shall be paid to the worker directly to their own bank account in legal tender. There are no payments “in kind” and any wages calculated on a performance related basis shall ensure the worker does not earn less that the legal minimum wage.

Workers shall not be held in debt bondage or forced to work to pay off any actually incurred or inherited debt.

Any deductions from wages shall not exceed the limits prescribed in national law and the company shall not make any unauthorised deductions.


MIGRANT WORKERS AND HUMAN TRAFFICKING AND FORCED LABOUR

Migrant workers, irrespective of their legal status shall be treated fairly and shall benefit from work no less favourable that those available to local workers and they shall have the right to enter into and terminate employment with reasonable notice in line with local laws and collective agreements.

Practices such as confiscating or withholding worker identity documents or other valuable items are prohibited.


EMPLOYMENT AGENCIES

We shall ensure that such agencies do not engage in fraudulent practices that place workers at risk of forced labour and trafficking for labour exploitation.

We shall take immediate and effective measure to prevent and eliminate the engagement of children in any form of child labour through an employment agency.

We shall use only those agencies licenced or certified by a competent authority.

We shall regularly audit labour suppliers.


ENFORCEMENT OF THIS POLICY

The Company shall prepare an annual statement under section 54 of the Modern Slavery Act 2015 outlining the steps being taken to ensure both the Company and its supply chain are free of slavery.