Modern Slavery Policy

Modern Slavery Act 2015

Introduction by Chris Scott

We, at Dams Furniture (including Dams Holdings) have a zero-tolerance to bribery and human trafficking and we are committed to high standards of ethics and integrity, which shows in all our business activities.

We are also committed to ensuring that there is transparency in our supply chain and we request that all of our suppliers comply with the standards we set as a company, trying in this way to not only comply with government regulations but moreover to eradicate modern slavery and human trafficking.

Organisation Structure

Dams Furniture (including Dams Holdings) is an office and contract furniture manufacturer and wholesaler. We have an annual turnover that exceeds £40M and our head offices are based in Knowsley, Merseyside, UK.

Dams Furniture (including Dams Holdings) is committed to the highest level of ethical standards and as a company set high standards of impartiality and integrity in the management of its activities.

Our Business

We supply office and contract furniture to our customers in UK and abroad.

Office Furniture Our customer’s, are divided in three main categories:
  • Dealers
  • Web/Retailers
  • Catalogue
Contract Furniture
  • Contractors
  • Public Sector
Our Supply Chain

Dams purchase a wide range of products and services from a diverse supply chain including:

  • Furniture components (bases, gas lifts, foam, metal legs, edging tape, boards, etc.)
  • Finished Goods (seating products, workstations, etc.)
  • Facilities Management Services and utilities
  • Communications and IT equipment services (hardware, software, licences)
  • Recruitment Agencies
  • Advertising, Communications & Marketing Services
  • Stationary
  • Temporary Staff and professional services
Our Policies on Slavery and Human Trafficking

Our procurement activities take place in England. Our suppliers are UK, EU and Far East based. Our total procurement value is in the range of £25M per annum.

We expect our suppliers and other companies we engage with to ensure their goods, materials, services and labour-related supply chains:

  • Fully comply with Modern Slavery act 2015
  • Are transparent, accountable and auditable
  • Free from ethical ambiguities

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Supplier Agreements reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Our safeguarding policies include specific guidance for staff on how to recognise signs of abuse, including slavery, human trafficking, forced labour and how to respond to and escalate any concerns.

Due Diligence processes for slavery and human trafficking

As part of the steps taken to ensure compliance with the Modern Slavery Act 2015, we have required our existing suppliers to provide official confirmation of transparency in their supply chains. For new suppliers wishing to engage with our company we require a Pre-Qualifications Questionnaire to be completed which includes questions targeted at the risks of slavery and human trafficking. In this way we can identify the risk and take all the necessary actions.

Furthermore, we expect our suppliers to provide relevant supportive evidence proving their statements.

We have in place systems to:

  • Identify and assess potential risk areas in our supply chains
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains
  • Monitor potential risk areas in our supply chains
Supplier adherence to our values and ethics

We employ a zero tolerance approach to slavery and human trafficking. To ensure all those in our supply chain (suppliers and sub-suppliers) comply with our values and ethics, we have in place rigorous selection, due diligence and various processes which help ensure our suppliers and their supply chains are slavery free.

We encourage anyone, including colleagues, suppliers, sub-suppliers, customers, to report in good faith any issue or concerns about potential unethical business practices, such as fraud and bribery or slavery and human trafficking through our duly authorised Directors.

Steps we have taken

Management Responsibility and general awareness

We have:

  • Agreed management responsibility for this policy and statement from our Senior Management Team and Board of Directors
  • Raised general organisational awareness by circulating an article to all staff explaining progress in preparing this statement via a company email
Risk Assessment

We have:

  • Undertaken an assessment using our procurement team to determine our risk exposure.
  • Included the Modern Slavery Act 2015 within our Statutory and regulatory compliance risk register to ensure the risk continues to be flagged, assessed and appropriately addressed
Risk Mitigation

We have:

  • Added a new clause to our Suppliers’ Agreements that permits Dams International to proceed to immediate contract termination in the event of a modern slavery or human trafficking compliance breach by the supplier
Steps to take Management Responsibility and general awareness

We will:

  • Report progress to our Senior Management Team and Board of Directors
  • Raise awareness of this published statement by notifying organisations with which we regularly engage
  • Prepare the annual statement
  • We will request all our suppliers to confirm their continued compliance of the above on an annual basis and inform us immediately when something changes
Risk Assessment

We will:

  • Undertake a review of this policy analysing our activities to establish whether the approach we have taken follows emerging best practice
  • Keeping up to date with any recent or emerging case law and best practice
  • Benchmarking our activities against statements and action plans undertaken by similar organisations
  • Re-evaluating the risk of non-compliance as part of our circular compliance risk register assessment
Risk Mitigation

We will:

  • Act promptly where a compliance breach has been identified or flagged
  • Continue to feed-back lessons learnt into the compliance risk management process

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Company’s slavery and human trafficking statement for the financial year ending 30th of September 2018.

  • Chris Scott
  • Managing Director
  • Dams Furniture
  • June 2019
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