Modern slavery Act

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person's liberty besides being a violation of various fundamental human rights. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery, servitude, forced or compulsory labour and human trafficking. Policy Statement

Policy Statement

At DLT APPS LIMITED, we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We are committed to acting ethically and with integrity in all our business dealings, relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere at DLT APPS LIMITED.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. 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, or anyone held in slavery or servitude, and we expect that our suppliers will hold their own suppliers to the same high standards.

Applicability of the Policy

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives and business partners. This policy does not form part of any employee’s contract of employment and we may amend it at any time. Current geographies we work

• United Kingdom
• India

RESPONSIBILITY FOR THE POLICY

The HR & Operations Department has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it The Head HR & Operations and CEO are primarily responsible for implementing, monitoring its use and effectiveness, dealing with any queries about the policy. Auditing internal control systems and procedures to ensure they are effective in countering modern slavery will be done on regular basis. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given any required training.

Policies

Supplier due diligence

DLT Apps Limited, conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. This includes:

• Assessing risks in the provision of services
• Auditing the suppliers, and their health and safety standards, labour relations and employee contracts
• Requiring improvements to substandard employment practices
• Sanctioning suppliers that fail to improve their performance in line with our requirements

COMPLIANCE WITH THE POLICY

Everyone must ensure that they read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of DLT Apps business or supply chain is the responsibility of all those working for us or under our control.
You are required to avoid any activity that might lead to, or suggest, a breach of this policy. Notify your manager OR the HR & OPs Department is a must if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
You are encouraged to raise concerns about any issue of suspicion of modern slavery in any parts of our business or the supply chains of any supplier tier at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible.
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, raise it with your manager or the Procurement Department. We aim 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 part of our supply chain. If you believe that you have suffered any such treatment, you should inform your manager immediately.

Awareness

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

At company level we have raised awareness of modern slavery issues by putting up posters, training our staff and sending an email that is focused specifically on modern slavery to all our staff, which explains:

• Our commitment in the fight against modern slavery
• Red flags for potential cases of slavery or human trafficking
• How employees should report suspicions of modern slavery

Training

At DLT Apps Limited and for our suppliers we have rolled out a fresh e-learning course to all employees and supplier contacts, which covers:

• Various forms of modern slavery in which people can be held and exploited
• The size of the problem and the risk to our organisation
• How employees can identify the signs of slavery and human trafficking, including unrealistically low prices How employees should respond if they suspect slavery or human trafficking
• How suppliers can escalate potential slavery or human trafficking issues to the relevant people within their own organisation
• What external help is available for the victims of slavery.
• What terms and guidance should be provided to suppliers in relation to slavery policies and controls
• What steps DLT Apps Limited will take if a supplier fails to implement anti-slavery policies or controls DLT Apps Limited anti-slavery policy. Anti-Slavery Policy is a part of DLT Apps Limited’s employee handbook and every employee must acknowledge and attest that they abide by the policy.

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, suppliers and organisations working on our behalf if they breach this policy.

References of Government

UK - https://www.gov.uk/government/collections/modern-slavery#national-referral-mechanism
India - https://wcd.nic.in/sites/default/files/DRAFT%20TRAFFICKING%20IN%20PERSONS%20%28PREVENTION%2C%20CARE%20AND%20REHABILITATION%29%20BILL%202021%20%281%29.pdf
Modern Slavery Acts – UK – Modern Slavery Act 2015, 2020 India - Slavery Act 2018, Human Trafficking, Prevention, Care and Rehabilitation Bill 2021

Updated: 6th Feb 2024