This is the anti-slavery policy of Axians DC LC and group of companies (“us”, “we”, “our”).

Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor, and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Axians DC LC is committed to acting ethically and with integrity in our business dealings and relationships and is committed to preventing modern slavery in our own business or to help prevent modern slavery in our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the UK Modern Slavery Act 2015 and all related legislation in all the jurisdictions we operate. We expect the same high standards from all of our employees and suppliers.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, suppliers, seconded workers, interns, contractors, external consultants, third-party representatives, and business partners. This policy does not form part of any employee’s contract of employment and we may amend it at any time.

Responsibility for the policy

The Executive Management has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The People Department has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal procedures.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

Compliance with the policy

The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your line manager (or your main point of contact at Axians DC LC, if you are a supplier) as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible. If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your line manager (or your main point of contact at Axians DC LC, if you are a supplier) or report it to a member of the Executive Team.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, you should raise it with your line manager (or your main point of contact at Axians DC LC, if you are a supplier) or report it to a member of the Executive Team.

We encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment by Axians DC LC as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavorable treatment connected with raising a concern. If you believe that you are suffering or have suffered any such treatment, you should inform any member of the Executive Team immediately. If the matter is not remedied, and you are an employee, you should raise a grievance.

This Modern (Anti) Slavery Policy and Statement applies to our businesses in all countries.

Communication & awareness of this policy

Guidance on this policy forms part of the induction process for all individuals who work for us and will be provided otherwise as necessary.

Breaches of this policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.

Last updated: October 17, 2022