Anti-slavery and Human Trafficking

ANTI-SLAVERY & HUMAN TRAFFICKING

Issue 1 Rev 3
Effective Date 01/2025

Policy Statement
Dalton Group Ltd strictly prohibits the use of modern slavery and human trafficking in
any part of our business operations or supply chains. We are committed to operating
with integrity, transparency, and responsibility and to implementing robust systems
and controls to ensure modern slavery is not taking place within our organisation or
with those working on our behalf.
This Policy applies to all persons working for us in any capacity, including employees
at all levels, directors, agency workers, contractors, and suppliers.
Dalton Group Ltd reinforces this commitment through clear policies, ongoing training,
supplier due diligence, and regular communication across the business.

Commitments
We shall be a company that expects everyone working with us or on our behalf to
support and uphold the following principles and actions to safeguard against modern
slavery:

• We have a zero-tolerance approach to modern slavery and human
trafficking within our organisation and across our supply chains. If we find that
an individual or organisation working with us has breached this policy, we will
take appropriate action. This may include remediation steps or the immediate
termination of the relationship, depending on the nature and severity of the
breach.

• All individuals working for us share the responsibility to prevent, detect, and
report any concerns relating to modern slavery. We provide training to raise
awareness and ensure that staff can identify signs of exploitation or forced
labour.

• We assess and monitor risk areas in our supply chains, particularly where
operations involve goods or services from higher-risk sectors or countries.

• We conduct due diligence on new suppliers before engagement and
regularly review existing suppliers for ethical compliance. 

• All suppliers are required to confirm adherence to this policy and must accept
contractual terms that reflect our ethical expectations, including compliance
with the Modern Slavery Act 2015 and the Ethical Trading Initiative Base
Code.

• We are committed to sourcing responsibly and expect our suppliers to
maintain fair labour practices, including freedom from forced labour, child
labour, and exploitative conditions.

• Our recruitment processes include strict right-to-work checks and a
commitment to fair and transparent hiring procedures, ensuring that no
individual is employed against their will.

• We have policies in place, such as our Whistleblowing Policy and Dignity
at Work Policy, to encourage employees to raise concerns safely and
confidentially, without fear of retaliation.

• We continually review and update our internal procedures, training, and
supplier monitoring efforts to stay aligned with best practice and evolving
legislation.

This policy is reviewed annually and is approved by the Director. Any breach of this
policy by employees will be treated as a disciplinary matter, and breaches by
suppliers or contractors may result in termination of contracts.

Stephen Dalton
Director