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Modern Slavery and Human Trafficking Statement

Introduction

Modern day slavery is a grave violation of human rights that affects millions of people worldwide. It encompasses various forms of exploitation, including forced labour, human trafficking, debt bondage, and child labour. Despite international efforts to combat this issue, modern slavery persists in many industries and regions, often hidden from plain sight.

This statement sets out The DDC Group’s actions to understand all potential modern slavery risks related to its own business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 January 2024 to 31 December 2024.

As part of the outsourcing sector, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.

Our organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking by ensuring:

  • We are dedicated to raising awareness and education within all of our business entities.
  • Compliance with legislation and enforcement of the laws protecting victims and prosecuting perpetrators.
  • Promotion of ethical labour practices and supply chain transparency in our business entities to ensure that products and services are free from exploitation.
  • Encouragement of international co-operation and partnerships to share knowledge, resources, and strategies in the fight against modern slavery.

 

Organisational structure and supply chains

This statement covers the activities of The DDC Group:
  • We are a highly experienced BPO and Customer Experience services provider utilising a balanced blend of people, technology, and location to offer solutions that are measurable, agile and innovative.
 
Countries of operation and supply

We currently operate in the United Kingdom, the US, Bosnia and Serbia, India, and the Philippines.

 

Relevant policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing policy - We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can contact their line manager or other appropriate person in the organisation who will in turn ensure the allegations are investigated.

  • Employee code of conduct - In our induction we make clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour as part of our organisations culture.

  • Management of Suppliers Process/Procedure - We are committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of our supplier code of conduct will lead to the termination of the business relationship.

  • Recruitment - We use only specified, reputable employment agencies to source labour (where required) and always verify the practices of any new agency it is using before accepting any workers from that agency.

 

Due diligence

As part of our commitment to identify and eradicate slavery and human trafficking from within our business and from those businesses with which we interact, we :

  • Work closely with our supply chains to ensure compliance with legislative obligations and we expect those organisations to have suitable anti-slavery and human trafficking policies and processes.
  • We seek to build long-standing relationships with suppliers and to make clear our expectations of ethical business behaviour from them.
  • We have in place systems to encourage the reporting of concerns and the protection of whistleblowers.

 

Training

We require senior managers and HR professionals within our organisation to complete training on modern slavery.

To ensure appropriate levels of risk awareness in respect of modern slavery and human trafficking, we provide training to relevant members of staff and, in particular, to Senior Managers and our Human Resources Department. All Directors and Leaders in the business have also been briefed on the subject.

 

Awareness-raising programme

As well as training staff, we have raised awareness of modern slavery issues by providing information on our organisations intranet which explains to employees the basic principles of the Modern Slavery Act 2015;

  • how employers can identify and prevent slavery and human trafficking;
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within our organisation; and
  • what external help is available, for example through the Modern Slavery Helpline: Modern Slavery Helpline

Ending modern day slavery requires a collective effort from all sectors of society, and we are committed to being part of the solution.

 

Executive Approval

This statement was approved on 22 November 2024 by our Group Chief People Officer who will review and update it annually.


Tracy Thornton

Group Chief People Officer