Owner Driver Anti-slavery and Human Trafficking Policy

1. Introduction

About this Policy:-
The United Nations Charter of Human Rights says that:-
o No one shall be held in slavery or servitude;
o No one shall be required to perform forced or compulsory labour.
Despite the terms of the Charter, slavery still exists. Modern slavery is a hidden crime that
affects every country in the world – including the UK.
What is modern slavery? it refers to situations where:-
o victims are exploited/taken advantage of for someone else’s benefit;
o victims cannot refuse to work or cannot leave a situation because of threats,
violence, bullying, lies, and/or abuse of power.
We have promised to act ethically and with integrity in our business and to put in place
systems and controls to make sure modern slavery is not taking place anywhere in our
business or in the business of any of our suppliers.
We set high standards for ourselves and expect the same high standards from all our
suppliers and other business partners including our Owner Driver Franchisees and
Workers.
If you, your Driver or any other Personnel break the terms of this Policy, we will end your
Franchise Agreement/Worker Contract.
We may change this Policy at any time and we will review it regularly.

2. What does Modern Slavery Look Like?

You may have read about Modern Slavery online or in the papers. Some of the situations you
will have read about will not apply to your work with DPD. We have set out a description of
something that has happened outside DPD so you can see an example of Modern Slavery. This
is a serious example, but you need to look at situations and ask yourself questions about
whether someone is being exploited.

Example

Workers were recruited in Country A by an English labour agency. The agency had promised the minimum wage, good accommodation for £50 per person per week, and lots of overtime
The Workers did not receive work or wages in their first week.
The Workers signed contracts, but the contracts were in English and they did not speak or read English so they did not know what they were signing.
Although the Workers were sleeping on the floor in the kitchen and sitting-room (and the legal maximum rent for those on the minimum wage is £58.52), they were told they must pay rent of £75 each. This was deducted weekly from their pay.
Several of the Workers were given the same National Insurance number. They had tax deducted at a high emergency rate. The Tax Office said it had not yet received payments for them.
After deductions, they were getting just £115 a week for 40 hours (£2.88ph). Another £15 disappeared without explanation. Most had not registered with the Home Office because they could not afford the fee, but this made them vulnerable to deportation. The Workers finally managed to escape.

3. Your Requirements

1. Keeping to this policy
1.1. You must make sure that you, your Drivers and your Personnel read, understand and
keep to this policy.
1.2. You must not do anything that might lead to, or suggest, that this policy has been
broken or might be broken.
1.3. You must tell Dan Turner (dan.turner@dpdgroup.co.uk), Rob Cheeseman
(rob.cheeseman@dpdgroup.co.uk) and Sund Paul (sund.paul@dpdgroup.co.uk), as
soon as possible if you believe or suspect that the terms of this policy have been
broken, or may be broken in the future.
1.4. You are encouraged to raise concerns about any issue or suspicion of modern slavery
in any parts of our business or any supplier tier as soon as possible.
1.5. If someone does something or treats their workers in any way which you think is not
right, but you do not know if it is modern slavery, please tell Dan Turner, Rob
Cheeseman and Sund Paul in confidence, as soon as possible.
1.6. We will support anyone who tells us in good faith about something under this policy,
even if they turn out to be mistaken. No one will be treated any differently if they make a
report in good faith. If you believe that you have treated any differently because of an
issue you have raised, please tell Dan Turner, Rob Cheeseman and Sund Paul in
confidence, as soon as possible.

2. Communication
This Policy is available through the DPD Academy. Each Driver has access to the DPD
Academy through their own log in details. It is your responsibility to make sure that all of
your Drivers and other Personnel read, understand and keep to this policy.

3. If you, your Driver or any other Personnel break the terms of this Policy, we will terminate
your Contract for Services.

Anti Bribery & Corruption

1. ABOUT THIS POLICY

1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
1.2 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any Service Provider or supplier who breaches this policy may have their contract terminated with immediate effect.
1.3 This policy does not form part of any employee’s or worker’s contract of employment or engagement and we may amend it at any time.

2. WHO MUST COMPLY WITH THIS POLICY?

2.1 This policy applies to all persons working for, or providing services to us, or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

3. WHAT IS BRIBERY?

3.1 ‘Bribe’ means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
3.2 ‘Bribery’ includes offering, promising, giving, accepting, or seeking a bribe.
3.3 All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with a representative of the Management Team either in person or by email to compliance@h2ologistics.co.uk.
3.4 Specifically, you must not:
a)   give or offer any payment, gift, hospitality, or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
b)   accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;
c)   give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure;
3.5 You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

4. GIFTS AND HOSPITALITY

4.1 This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.
4.2 A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).
4.3 Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in our name, not your name.
4.4 Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers, and business partners.

5. RECORD-KEEPING

5.1 You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.
5.2 All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

6. HOW TO RAISE A CONCERN

6.1 If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify a representative of the Management Team either in person or by email to compliance@h2ologistics.co.uk.