D.A. Languages Ltd condemns modern slavery in all forms and acknowledges the seriousness and impact of this problem that affects millions of people in both developed and developing countries. With this in mind, D.A. Languages Ltd is committed to ensuring slavery and human trafficking does not exist in its operation or supply chains. This statement defines the steps taken by the company to combat modern slavery and efforts made to understand potential risks and complexities surrounding the issue.
This statement regarding Modern Slavery applies to D.A. Languages Ltd. The information included in this statement refers to the financial year 1st July 2019 to 30th June 2020.
B) ORGANISATIONAL STRUCTURE
D.A. Languages Ltd is a limited company, established in 1998. Currently based in Stretford, Manchester, we provide interpreting and translation services nationally and throughout the UK. Demand for our services is consistently high throughout the year and is not subject to seasonal change. The services that D.A. Languages Ltd supplies to its client are carried out in various locations throughout the United Kingdom, but primarily in England.
D.A. Languages Ltd is under the control of the company director, Actar Arya. Following this, there is the Managing Director: Matthew Taylor, Finance Director: Annette Silcock, Operations Director: Matthew Barrington, Emma Whitemoss: Risk, Compliance & HR Manager, Head of Sales: Joe Williams, Business Development Manager: Dave Murray and Client Account Manager: Lauren Tew. To assist the management are the team leaders: Ruth Entwistle and Debbie Pye who are head of Administration and head of Booking respectively.
• Forced work through mental or physical threat • Being owned or controlled by an employer through mental or physical abuse, or the threat of abuse
• Being dehumanised, treated as a commodity or being bought and sold as property
• Being physically constrained, or to have restriction placed upon an individual’s freedom of movement.
D.A. Languages Ltd acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions outlined in the Modern Slavery Act of 2015. D.A. Languages Ltd understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
D.A. Languages Ltd does not enter into business with any other organisation, whether in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to D.A. Languages Ltd in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. D.A. Languages Ltd strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in United Kingdom and in many cases exceeds those minimums in
relation to its employees.
E) SUPPLY CHAINS
In order to fulfil its activities, D.A. Languages Ltd’s main supply chains include those related to interpreting and translation services in both the United Kingdom and overseas. We understand that D.A. Languages Ltd’s first-tier suppliers are intermediary traders and therefore have further contractual relationships with lower-tier suppliers.
F) POTENTIAL EXPOSURE
D.A. Languages Ltd considers its main exposure to the risk of slavery and human trafficking as being through the use of 2nd tier providers. A 2nd tier provider refers to a separate
company who may assist our agency in supplying a service to a client. While we trust that our 2nd tier providers aim to tackle modern slavery and carry out their own due-diligence in the prevention of slavery and human trafficking; we note that as an entities outside of our control, we cannot direct their actions. With that said, the steps taken in light of these risks
can be seen in section G) STEPS, below and also in I) Policies.
In general, D.A. Languages Ltd considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business, or the business of any organisation that supplies goods and/or services to it.
D.A. Languages Ltd carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
D.A. Languages Ltd has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, D.A. Languages Ltd has taken the following steps to ensure that modern slavery is not taking place: • An annual review of supplier contracts to identify and assess the potential risks in its
supply chains. This includes power of contract termination in the event that the supplier is, or is suspected, to be involved in modern slavery.
• An annual assessment of its services concerning potential instances of slavery and reporting of actions taken to address the risk to modern slavery, all included in the Modern Slavery Statement
• D.A. Languages Ltd has a zero tolerance policy towards modern slavery. There is no exception to this and applies to all workers within D.A. Languages Ltd.
H) KEY PERFORMANCE INDICATORS
D.A. Languages Ltd has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in D.A. Languages Ltd or its supply chains.
• Implementation and annual review of all Policies that further define the Modern Slavery Statement
• In line with the Modern Slavery Act 2015 we will review and update the Modern Slavery Statement annually to confirm the actions taken to ensure slavery and human trafficking is not taking place in our supply chain or own business.
D.A. Languages Ltd has the following policies which further define its stance on modern
• The Ethical Trading Initiative Policy • Abuse Policy • Corporate Social Responsibility Policy • Recruitment Policy and Procedure
• Whistleblowing Policy – If any one of our employees, customers or suppliers
suspects acts of slavery in any form, or mistreatment, they are encouraged to report
their suspicions without fear of retaliation and that they can do so in confidence.
• Professional Code of Conduct – In tandem with our whistleblowing policy, our
employees are encouraged to do the right thing by clearly stating the actions and
behaviour expected of them when representing the business.
• Preferred Supplier List – D.A. Languages Ltd operates a supplier policy and conducts due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy. In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:
1. They have taken steps to eradicate modern slavery within their business
2. They hold their own suppliers to account over modern slavery
3. (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate)
4. (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations
We may terminate the contract at any time should any instances of modern slavery come to light.
J) SLAVERY COMPLIANCE OFFICER
D.A. Languages Ltd has a Slavery Compliance Officer, Actar Arya, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the D.A. Languages Ltd’s obligations in this regard.
This statement is made in pursuance of Section 54 (1) of the Modern Slavery Act 2010 and will be reviewed for each financial year.