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 risk and compliance solutions company with a duty to operate its business in an ethical, fair and responsible manner. DFIN provides software as a service (SaaS) products, software-enabled services (SeS), print, and compliance services related to US Securities and Exchange Commission regulations to companies in capital and investment markets. Therefore, DFIN consider that the risk of any form of bonded labour, child labour, forced labour, slavery, trafficking or workplace abuse (“Modern Slavery and Related Human Rights Abuses”) existing within its supply chain is low.
Structure, business and supply chains
DFIN is headquartered in the United States of America and is present in other locations worldwide, including Europe, South America and Asia Pacific. Donnelley Financial Solutions UK Limited (“DFIN UK”) is 100% beneficially owned by DFIN and its business is primarily based in the UK and Europe.
Further details about our group can be found at ‘About Us’ at: About Donnelley Financial Solutions (DFIN) | Risk & Compliance Solutions (dfinsolutions.com).
Given the nature of DFIN’s business, eradicating Modern Slavery and Related Human Rights Abuses in our supply chain is essentially our suppliers’ responsibility. However, we continue to be mindful of any possible risks and take the following measures:
- 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 and suppliers 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 of zero tolerance to Modern Slavery and Human Rights Abuses;
- Policies: Collectively, our internal and external policies prohibit any threat of violence, harassment, intimidation, forced, bonded, indentured labour, child labour, discrimination, surrender of government-issued identification, passports or work permits. Employees have freedom to terminate their employment. Additionally, DFIN has developed a global Supplier Code of Conduct for our suppliers to adhere to, which represents a high-level summary of our key policies, standards, and commitments, including on respecting human rights and requiring everyone we work with to operate responsibly. DFIN’s Supplier Code of Conduct can be found here: Supplier_Code_of_Conduct_Global_8-2021.pdf (dfinsolutions.com).
- Audit: DFIN monitors and continues to develop its strategy on preventing Modern Slavery, throughout the year, with relevant policies and training modules updated on an annual basis.
- Due Diligence: When assessing our suppliers, we consider the nature and severity of the risk, the level of influence a business may have over its own supply base and the level of influence DFIN may have over that supplier. DFIN has created questionnaires as part of its onboarding processes and due diligence evaluation of its suppliers that, amongst other things, deals with suppliers’ compliance with the UK Modern Slavery Act 2015.
- 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 our suppliers).
Wherever possible, DFIN uses its own standard terms and conditions for contracts, which require suppliers to comply with all applicable laws, statutes and regulations including the Modern Slavery Act 2015. We require suppliers to notify us of any breach or potential breach of these conditions.
- Remedies; Dealing with Infractions DFIN 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 will work with the supplier to remedy the violation if it believes that it is capable of remedy. DFIN 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.
- KPIs: We will continue to measure the success of our approach against the following:
- No reports of any incidences of modern slavery within our business;
- Our employees’ familiarity with policies that enable them to report any concerns; and
- Our suppliers understanding the importance of ensuring that modern slavery is not taking place within their supply chain and the consequences of not taking effective action.
- Training: DFIN has a mandatory training module for all new employees that join the company, and periodic training for 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 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 will continue to review its position with a view to evolving its policy on the Modern Slavery Act and encourage a proactive role of all employees 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 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 19 December 2023
Tuan-Jin Aw - Director
Robert Wilson – Director
Matthew Gould – Director
Jeremy Hall - Director