Modern Slavery and Human Trafficking Policy

This policy is pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Dolby Vivisol has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Dolby Vivisol is committed to driving out acts of modern-day slavery and human trafficking within its business and from within its supply chains, including sub-contractors and partners.

Dolby Vivisol has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

The company will not support or deal with any business knowingly involved in slavery or human trafficking.

Dolby Vivisol takes a risk-management approach to ethical procurement. This means that we focus on identifying and addressing key vulnerabilities to eliminate slavery in our supply chain. We value and enforce the respect for human rights, including children’s rights across our supply chain and this is built into contracts and represented in dialogue, self-assessment, audits, training and capacity building opportunities for suppliers, subcontractors and other business partners.

Our due diligence process includes a review of all suppliers to assess whether it is a relevant organisation as defined by the Act and if deemed so, we will request a copy of their Modern Slavery statement or equivalent to ensure it aligns with our own and the legislative requirements.

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. They pay their employees at least the national minimum wage / national living wage as currently legislated
4. We may terminate the contract at any time should any instances of modern slavery come to light

We operate under a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. Ethical policy. This policy sets out the organisation’s stance on slavery and explains how employees can identify any instances of this and where they access help or guidance.
2. Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
3. Corporate Social Responsibility Policy. We operate a CSR policy so that all employees understand that the company recognises and values the importance of integrity and transparency in all business interactions. This policy accommodates the reporting of modern slavery issues in the business and in the supply chain.
4. Anti-Bribery Policy. The Company is fully committed to instilling a strong anti-corruption culture and is fully committed to compliance with all anti-bribery and anti-corruption legislation including, but not limited to, the Bribery Act 2010 (“the Act”) and ensures that no bribes or other corrupt payments, inducements or similar are made, offered, sought or obtained by us or anyone working on our behalf.

We have a dedicated compliance manager, the Human Resources Director, who has primary and day-to-day responsibility of auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Dolby Vivisol Directors and senior management shall take responsibility for implementing this policy and its objectives, and shall provide adequate resources, including training of all staff through their induction process, plus investment to ensure that slavery and human trafficking is not taking place within either the organisation or its supply chains.
A full copy of this policy and a copy of the Modern Slavery Act 2015 are accessible to all employees electronically through the company Intranet, and may be obtained from the HR Department on request.

Formal procedures concerning slavery and human trafficking have been established including disciplinary procedures when any breach occurs. Additional procedures ensure that this policy is understood and communicated to all levels of the company and is regularly reviewed by the Managing Director to ensure its continuing suitability and relevance to company activities.

Signed on behalf of Dolby Vivisol on 24 February 2023

Name: Stephen Cottee
Position: Managing Director