This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015.
Doulton Development Limited ('the Company', 'we', 'us' or 'our') is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.
Doulton Development Limited has business operations in the United Kingdom.
We operate in the property development and investment sector. The nature of our supply chains is as follows: We work with several key direct UK suppliers, who are industry regulated, and who provide us with goods and services connected to the property development and investment industry. They also supply equipment for our premises, and services, such as outsourced business processes, IT software and legal services.
For more information about the Company, please visit our website: https://www.graphitesquare.uk/about-us/.
We operate several internal policies to ensure that we are conducting business in an ethical and transparent manner.
These include the following:
• Recruitment and selection policy- We conduct checks on all prospective employees to verify that they are eligible to work in the UK.
• Whistleblowing policy- We operate this policy so that employees are able to raise concerns about how staff are being treated or practices within our business or our supply chains without fear of reprisal.
• Staff code of conduct- We are committed to the fair treatment of all staff. Our staff code of conduct reflects our core values and expected behaviours. The code of conduct makes it clear that we have a zero-tolerance approach to modern slavery.
We make sure our suppliers are aware of our policies and adhere to the same standards.
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:
• External supplier audits.
Our due diligence procedures aim to:
• Identify and action potential risks in our business and supply chains.
• Monitor potential risks in our business and supply chains
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
• Provide protection for whistle-blowers.
Risk and compliance
The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:
• Evaluating the slavery and human trafficking risks of each new supplier.
• Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping.
We do not consider that we operate in a high-risk environment because the majority of our supply chain is based in the UK and in low-risk industries, such as property development and investment, software, and services. We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately.
The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:
• We will carry out a regular audit of suppliers - 10% of suppliers each year.
The statement was approved by the board of directors.
Steve Dunn, Director Graphite Square Property Co Limited
Date 24 October 2023