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Modern Slavery & Anti-Trafficking

Document Reference: KB/ModSlav, Version 4 January 2023

This Danesmoor Holdings Ltd. Policy is approved by the Board; it represents the Danesmoor Holdings Ltd. Board’s direction to the business on this topic. Compliance with this policy is mandatory through aligning Danesmoor Holdings Ltd. group companies’ processes and people behaviours to the commitments below.

Policy Statement

This Danesmoor Group Ltd. policy statement covers all entities in the Group required to report under the Modern Slavery Act 2015; that is, PWS Distributors Ltd., Danesmoor Ltd. and Life-Kitchens for Living Ltd.  The information included in the statement refers to the financial year 2022/2023.

This policy applies to all persons working for us at any of our sites within the UK including County Durham, North Yorkshire and London, or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers.  Danesmoor Group Ltd. strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain.  We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains.  

Modern Slavery and Human Trafficking

The Group considers that modern slavery encompasses:

  • Human trafficking
  • Forced work, through mental or physical threat
  • Being owned or controlled by an employer through mental or physical abuse or the threat of abuse
  • Being dehumanised, treated as a commodity or being bought or sold as property
  • Being physically constrained or to have restriction placed on freedom of movement

Commitments

The Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015.  The organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally its supply chains.

The Group does not enter into business with any other organisation, in the United Kingdom or abroad which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour and expect that our suppliers will hold their own suppliers to the same high standards.

No labour provided to the Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom

In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place: 

  • We have a zero-tolerance approach to modern slavery in our organisation and our supply chains. 
  • The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf.   Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy. 
  • We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain. 
  • We take a risk-based approach to our contracting processes and keep them under review.  We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties.  Using our risked-based approach we will also assess the merits of writing to suppliers requiring them to comply with our Sourcing Policy, which sets out the minimum standards required to combat modern slavery and trafficking. 
  • Consistent with our risk-based approach we may require: 
  • Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct;
  • Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Sourcing Policy.
  • As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Sourcing Policy. 
  • If we find that other individuals or organisations working on our behalf have breached this Policy, we will ensure that we take appropriate action.  This may range from considering the possibility of breaches being redressed and whether terminating such relationships might represent the best outcome for those individuals impacted by the breach. 

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

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