Introduction

This statement sets out EUROPEAN DYNAMICS’ actions to understand all potential modern slavery risks related to its 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.

EUROPEAN DYNAMICS (ED) recognises that it has a responsibility to take a robust approach to slavery and human trafficking. ED 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.

Relevant policies

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

Whistleblowing policy: ED encourages all its employees, customers and other business partners to report any concerns related to ED’s direct (or indirect through the supply chain) activities. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. ED’s whistleblowing procedure is designed to make it easy for workers to make disclosures without fear of retaliation.

Employee code of conduct: ED’s code of conduct makes clear to employees the actions and behaviour expected of them when representing the Company. ED strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

Supplier/Subcontractor code of conduct: ED is committed to ensuring that its suppliers and subcontractors adhere to the highest standards of ethics. Suppliers and subcontractors 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. ED works with suppliers and subcontractors to ensure that they meet the standards of the code and improve their employees’ working conditions. However, serious violations of ED’s supplier code of conduct will lead to the termination of the business relationship.

Due diligence

ED undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. ED’s due diligence and reviews include:

• mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
• evaluating the modern slavery and human trafficking risks of each new supplier;
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• conducting supplier audits or assessments which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular;
• invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators

ED has reviewed its key performance indicators (KPIs) in light of the introduction of the United Kingdom’s Modern Slavery Act 2015. As a result, ED:

• requires all staff to have completed training on modern slavery by six months after their employment commencement date;
• develops a system for its supply chain, whereby ED evaluates potential suppliers before they enter the supply chain;
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• reviews its existing supply chain twice per year, whereby ED evaluates all existing suppliers.