1. Our Commitments
2. Our Business Associates
3. Bribery and Corruption
4. Prevention of Tax Evasion Facilitation
5. Modern Slavery
6. Information Security
7. Data Processing
8. Environmental
9. Whistleblowing
10. Next Steps

We are committed to conducting our activities with integrity and respecting our legal, ethical, environmental and social responsibilities to protect our clients, employees, partners and those we do business with. We also recognise our societal duty to support governments, the communities in which we work, law enforcement and economic crime prevention as well as doing our part to protect the environment.

We are also committed to ensuring our information systems are secure and that the privacy of our clients is protected. We will not tolerate any deliberate breach of financial crime laws (e.g. tax evasion facilitation, bribery or money laundering), modern slavery in any form or any action that harms the environment.

We expect and require the people and firms, associated with us, that work for us or on our behalf, who we partner with, or who provide goods or services to us (“our Business Associates”) to abide by our above commitments which are set out in more detail below. We expect our Business Associates to have similar processes and controls in place for their Business Associates if they are involved in performing services for us or supplying goods to us. The requirement to abide by our policies and commitments is supplemental to any contract or agreement we have entered into with our Business Associates and remains in force until all obligations of our Business Associates has ceased. We require our Business Associates to notify us of as soon as they become aware that they have not or may not be able to comply with any of our commitments. Any material failure to comply may be considered a material breach of our contract with our Business Associates.

Specifically, our commitments and expectations of our Business Associates are set out below.

Worldwide, more than half the GDP of the UK is lost in bribes each year. Bribery and corruption can lead to the loss of a healthy environment and sustainable future. The principal legislation is the UK Bribery Act 2010 which reaches to anywhere a UK firm does business or its associated parties, subsidiaries etc. wherever they are located. We also comply with the Isle of Man Bribery Act 2013 which mirrors the UK version and the Corruption (Jersey) Law 2006.

We will not engage in, and do not expect our Business Associates to engage in:

• the offering, promising, or giving of a bribe
• the requesting, agreeing to receive, or accepting of a bribe
• bribing a foreign public official (which includes persons working for international organisations)

We will do all we can and expect our Business Associates to do all they can to prevent bribery. We conduct due diligence and risk assess and monitor our Business Associates. We have controls in place around gifts and entertainment, conflicts of interest, charitable donations and employment opportunities. We train our staff requiring them to be aware of the risks of bribery. We have an ongoing risk assessment programme.

Tax evasion is very damaging to the societies in which it occurs. It diverts money and resources from those who need them most, hindering economic and social development. Under the UK Criminal Finances Act 2017, as a corporate body we have a duty to prevent the criminal facilitation of tax evasion. That prevention extends to our Business Associates where they are acting on our behalf and extends to the facilitation of evasion of any tax or duty in any jurisdiction.

We will not assist or facilitate another party to evade taxes and we will report any party that asks us to do so. Similarly, we will not tolerate any Business Associates acting on our behalf to facilitate tax evasion.

We train all our staff in relation to tax evasion facilitation and the consequences of not acting with integrity. We risk assess our exposure to the possible tax evasion schemes or practices to which our business could potentially help facilitate, and put controls in place and monitor control effectiveness. Due diligence checks and our expectations are built into the processes, terms & conditions in relation to employment and, as outlined here, we have high expectations of our Business Associates conducting activities on our behalf.

It is believed there were over 6 million slaves worldwide in the 18th/19th century. This compares to estimates between 20 and 70 million today. It is the exploitation of people for personal or commercial gain and includes criminal and sexual exploitation, human trafficking, domestic servitude, forced labour and organ-harvesting. We recognise the construction sector is one of the highest risk industries for forced labour exploitation and it is why we believe in taking meaningful action to prevent this crime from taking place within our operations.

We will not tolerate any form or modern slavery and have no appetite to work with anyone who does not have sufficient controls in place to prevent it. We comply and expect our Business Associates to comply with all aspects of the UK Modern Slavery Act 2015 and have controls in place to detect and prevent it.

Our staff are trained to recognise signs of modern slavery and there are controls within our recruitment processes. We expect our Business Associates to let us know of any circumstances within their supply chain where modern slavery could be taking place or that could give rise to an investigation under the Modern Slavery Act 2015. We risk assess our vulnerability to modern slavery and undertake due diligence on our Business Associates.

People who are homeless and those excluded from society through modern slavery are particularly vulnerable to manipulation, grooming and exploitation. People who have fled slavery or been previously subjected to it may be sleeping rough. Shelters, soup kitchens and day centres are recruiting centres for those seeking to control victims. The Dandara Charitable Partnership (Registered Charity 1166309) provides grants for local charities and social purpose organisations for, amongst other things, the homeless and social inclusion.

We believe in protecting the confidentiality, integrity and availability of our and our client’s data beyond the obligations of that for individuals under the Data Protection Acts of the jurisdictions in which we do business (see Privacy Policy). Our information technology and cyber security systems are robust and modern, we use market leading providers to keep information secure including our email gateway and archive storage, web presence and endpoint security systems. Staff are trained on information security awareness and much of our infrastructure is compliant with ISO 27001.

It is sometimes necessary for us to share the personal data of our clients – be that a name and address provided to a contractor to fix a plumbing, electrical or similar issue, or it is inherent as part of the functioning of our business through the use of providers of information technology solutions and security software. When we need to allow our Business Associates to process the data that we control they must comply with our data processing requirements to ensure the data remains secure. We also expect our Business Associates to have their own data processing agreements in place with their Business Associates should there be a need to further process the data.

We are working on a detailed and exciting new environmental strategy which will be published soon.

We are committed to conducting our business with openness, transparency, accountability and integrity. We want to know about any wrong-doing that happens with regard to Our Commitments, any matter endangering health and safety, criminal acts or other matters of public concern, so we can act on them and learn from them. Our employees and Business Associates would likely be the first to identify any issues and we have a ‘speak up’ culture and encourage employees and our Business Associates to speak to line managers, site managers and business contacts. To maximise our ability to capture all genuine concerns and underline Our Commitments, we also have a confidential whistleblowing channel. Concerns are investigated by our Compliance, Legal, Tax and Human Resources teams and where substantiated we act upon them. Employees and our Business Associates can find out more or raise concerns at whistleblowing@dandara.com .

Whilst part of our information systems are already on the Cloud an ongoing project will give us 100% coverage by early 2023 which streamlines compliance. We are also in the process of maturing our information security environment through a programme to gain ISO27001 accreditation.

We will be enhancing our supply chain risk assessment processes in line with all of Our Commitments. We will also be making Modern Slavery a specific object of the Dandara Charitable Partnership.

We are reviewing our training systems with a view to enhancing training in all areas and where applicable extending that to our Business Associates.

We are investing significantly in our environmental, social, governance and compliance areas and will be changing and enhancing many of our processes in the near future which also includes our enterprise risk management framework.

Steven Hannah, Finance Director