COMPLIANCE STATEMENT – MODERN SLAVERY ACT 2015
This statement is made pursuant to S.54, Part 6 of the Modern Slavery Act 2015 and the requirement for certain businesses to provide disclosure concerning their efforts to address issues of modern slavery and human trafficking in their own operations and in their supply chain.
Donnelley Financial Solutions Inc (DFIN) is a global service provider and accordingly has a duty to operate its business in an ethical fair and responsible manner. DFIN operates an information technology and service based business and considers that the risk that any form of bonded labour, child labour, forced labour, slavery, trafficking or workplace abuse (“Modern Slavery and Related Human Rights Abuses”) exists within its supply chain is low.
Donnelley Financial Solutions UK Limited (“DFIN UK”) is 100% beneficially owned by DFIN and has its business primarily based in the UK and Europe. As an employer and as a part of each of the communities in which our sites are located, the expectations upon us are changing in line with the increased global focus on the role of business within Modern Slavery and Related Human Rights Abuses. DFIN UK is evolving its approach to engage with this changing landscape of corporate responsibility and reality of supply chain awareness. DFIN UK is continually reviewing its policies and procedures to take all steps necessary to prevent the risk of Modern Slavery and Human Rights Abuses occurring in its business.
Structure, business and supply chains
Eradicating Modern Slavery and Related Human Rights Abuses in our supply chain is essentially our suppliers’ responsibility however DFIN has undertaken the following actions:
- Strategic Approach: DFIN’s long term strategic goals include:
- Identifying High Risk Areas for Modern Slavery and Human Rights Abuses in its supply chain;
- Commit to contracting with its customers in an ethical manner that seeks (where applicable) to include appropriate measures to prevent Modern Slavery or Human Rights Abuses;
- Develop a lasting corporate legacy on DFIN zero tolerance policy to Modern Slavery and Human Rights Abuses;
- Develop an engaging staff training programme on the impact of the Modern Slavery Act.
- Develop a Code of Conduct for its suppliers to adhere to – to reflect the core ethical principles shares by DFIN and its business.
- Audit: DFIN will continue to monitor and develop its strategy on preventing Modern Slavery, which is currently reviewed throughout the year and with relevant policies updated on an annual basis.
- Due Diligence: In our assessment we will consider the nature of the risk, severity of the risk, the level of influence a business may have over its own supply base and the level of influence which may be interpreted that DFIN may have over that supplier.
- Self Assessment: Through our internal assessment, we are looking at varied ways to assess risk through specific country risks, sector risks, transaction risks and business partnership risks.
- Contractual Review: DFIN has reviewed its contractual documentation in order to fully understand its process of identifying and stopping any Modern Slavery and Related Human Rights Abuses, giving particular consideration to where applicable:
- Principles of Ethical Conduct of its customers and suppliers; and
- the UK Modern Slavery Act 2015 (in so far as it applies to the suppliers).
- Other Initiatives: DFIN has created an additional questionnaire as part of the onboarding processes and due diligence evaluation of its suppliers that, amongst other things, deals with suppliers’ compliance with the UK Modern Slavery Act 2015. Additionally, DFIN is in the process of developing a global Supplier Code of Conduct for our suppliers to adhere to.
- Remedies; Dealing with Infractions: DFIN UK will monitor any supplier it reasonably suspects of committing Modern Slavery and Human Rights Abuses and contact the supplier to further understand and investigate any potential violations. DFIN UK will work with the supplier to remedy the breach if it believes that it is capable of remedy. DFIN UK has incorporated robust termination rights into its contracts (with suppliers and customers) in order to terminate contracts where Modern Slavery and Human Rights Abuses are committed.
- Training: DFIN UK has reviewed its training modules and has a mandatory training module for all new employees that join the company, and periodic training to all current employees who may have to give consideration to Modern Slavery Act 2015 and will be required to identity potential circumstances where Modern Slavery and Related Human Rights Abuses may exist.
- Senior Sponsorship: Due to the low risk of Modern Slavery and Related Human Rights Abuses that DFIN has determined exists in its supply chain, DFIN UK will continue to review its position with a view to evolving its policy on the Modern Slavery Act and to involve a proactive role of employees and senior managers within the company. Meetings with senior management to develop and evolve the DFIN UK policies, preventing Modern Slavery and Related Human Rights Abuses, are planned on an annual basis.
- Reality Check: DFIN UK aims to encourage and foster a culture of disclosure to ensure that any Modern Slavery and Human Rights Abuses are reported at the earliest opportunity.
Signed for and on behalf Donnelley Financial Solutions UK Limited - Date September 2020
TUAN-JIN AW – DIRECTOR
MATTHEW GOULD - DIRECTOR
ROBERT WILSON – DIRECTOR
JERRY HALL – DIRECTOR