Anti-slavery and Human Trafficking Policy
This is a policy of the Danaher & Walsh Group Limited and its subsidiary companies, namely Danaher & Walsh Group Limited, Danaher & Walsh Civil Engineering Limited and Danaher & Walsh Pipeline Solutions Ltd.
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. These all involve one person depriving another person of their liberty in order to exploit them for personal or commercial gain.
The Danaher & Walsh Group Limited has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships.
We are also committed to implementing and enforcing effective systems and controls. These help ensure modern slavery does not take place in our own business or in any of our supply chains.
In addition, we are committed to ensuring transparency in our own business. We apply the same approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.
The UK Government provides further modern slavery and supply chain guidance.
We expect the same high standards from all of our contractors, suppliers and other business partners.
As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour. This also includes anyone held in slavery or servitude, whether adults or children.
In turn, we expect our suppliers to hold their own suppliers to the same high standards.
Scope of this Policy
This policy applies to all persons working for us or on our behalf in any capacity.
It includes employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
The policy does not form part of any employee’s contract of employment. We may amend it at any time.
Employees and other relevant parties should also refer to our wider company policies.
Responsibility for the Policy
The Managing Director has overall responsibility for ensuring this policy complies with our legal and ethical obligations.
The Managing Director also has responsibility for ensuring that all those under our control comply with it.
The Operations Director has primary and day-to-day responsibility for implementing this policy. This includes monitoring its use and effectiveness, dealing with any queries, and auditing internal control systems and procedures.
These audits help ensure our procedures remain effective in countering modern slavery.
Management at all levels must ensure those reporting to them understand and comply with this policy.
Managers must also ensure their teams receive adequate and regular training on this policy and on 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.
Please address comments, suggestions and queries to the Operations Director.
Compliance with the Policy
You must ensure that you read, understand and comply with this policy.
All those working for us or under our control share responsibility for preventing, detecting and reporting modern slavery in any part of our business or supply chains.
You must avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred.
You must also notify your manager if you believe or suspect that a conflict may occur in the future.
Reporting Concerns
We encourage you to raise concerns about any issue or suspicion of modern slavery at the earliest possible stage.
This applies to any part of our business or supply chains, at any supplier tier.
If you believe or suspect a breach of this policy has occurred, or that it may occur, you must notify your manager.
Alternatively, report it in accordance with our Whistleblowing Policy as soon as possible.
If you are unsure whether a particular act constitutes modern slavery, raise it with your manager or the Operations Director.
This includes concerns about the treatment of workers or their working conditions within any tier of our supply chains.
Protection for Those Raising Concerns
We aim to encourage openness.
Therefore, we 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 concerns in good faith.
This includes any suspicion that modern slavery of whatever form is, or may be, taking place in 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 you believe that you have suffered any such treatment, you should inform the HR Department immediately.
If the HR Department does not remedy the matter, and you are an employee, you should raise it formally using our Grievance Procedure.
Communication and Awareness of this Policy
Training on this policy forms part of the induction process for all individuals who work for us.
This training also covers the risk our business faces from modern slavery in its supply chains.
In addition, we will provide regular training as necessary.
We will communicate our zero-tolerance approach to modern slavery to all suppliers, contractors and business partners at the outset of our business relationship with them.
We will also reinforce this approach as appropriate thereafter.
Breaches of this Policy
Any employee who breaches this policy will face disciplinary action.
This 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.
Daniel Danaher
Managing Director
Danaher & Walsh Group Ltd
20 Granite Way
Mountsorrel, Leicestershire
LE12 7TZ
Company No. 03957969