DF Capital

Modern Slavery Act Statement 2018

Introduction

This statement sets out the actions which Distribution Finance Capital (DFCapital) has taken, and is continuing to take, to make sure that modern slavery or human trafficking is not taking place within our business or supply chain during the year ending 31 December 2018.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. DF Capital has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

How we exercise our zero tolerance policy

We do everything we can to be ethical and trustworthy in all aspects of our business. Here’s how we work our policy on modern slavery and human trafficking into this philosophy.

Our ethical employment practices

We are committed to conducting ourselves honestly and with integrity; striving for fairness in everything we do, including how we treat our employees. We have policies in place which ensure our employment practices mitigate the risks identified in the Modern Slavery Act, including:

  • Employees are not subject to any forced labour and have the freedom to terminate their employment at any time, without penalty, given the length of notice specified;
  • Employees will not be charged any fees for recruitment;
  • The confiscation or withholding of any worker identity documents is strictly prohibited;
  • Our workplace is free of any form of harsh or inhumane treatment and reinforced through staff training;
  • All Employees, irrespective of their nationality, are treated fairly and equally;
  • All Employees are paid at least the minimum wage required by law and wages are paid at regular intervals, directly to the member of staff;
  • Employees are not required to work in excess of the legally mandated number of hours;
  • Any and all overtime is voluntary, and no worker will be required to work overtime under the threat of penalty or dismissal.
Our whistleblowing policy

We operate a whistleblowing policy so that all of our staff are aware that they can confidentially report any concerns, including cases of unethical behaviour
within our business or supply chain, and we review every case that is reported and take appropriate action.

We’ll soon be training all our staff to be on the lookout

We want all our staff to know and understand the risks of people being exploited. So we’re planning a new training course that’ll make sure we all know how to spot the warning signs in our business and supply chain.

We scrutinise all our suppliers

We think carefully about the businesses we’re looking to work with. We have sensible checks in place to assess whether they are ethical, stable and trustworthy. Over the next year we will be adding checks for modern slavery into the mix and if we ever have any concerns about slavery or trafficking in a particular business, we will report it and refuse to do business with them.

Our Risk team checks our relevant supplier agreements are consistent with all the appropriate laws, and if we need to, we run the agreements past our HR, IT and Business Development teams too. We’re writing a new procurement policy that’ll set out this process clearly.

We’re making it one of the ways we measure our success

Like most businesses, we use key performance indicators (KPIs) to measure how well we’re doing in different areas of our business. Most KPIs are based on productivity and performance statistics, but we’re taking it a step further. From next year, we’ll be looking at what KPIs we can set to measure how well we’re enforcing our zero tolerance policy on slavery and trafficking ensuring it’s not happening in our business or supply chains.

We’ll update you on our progress again next year

We support the government’s call to arms on this issue. We are starting our journey to understand and identify what we can do to help in the fight to end modern slavery and human trafficking, and we’ll update our statement with our latest actions every year.