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Bribery Act 2010, Modern Slavery Act 2015, and Criminal Finances Act 2017 Statement

Introduction.

Diafora is committed to ensuring that its business is conducted with integrity, transparency and fairness and in compliance with all relevant rules, regulations and legislation.

This means that the Company is committed to the prevention of bribery and the facilitation of tax evasion. The Company has processes in place to ensure that its procedures to prevent bribery and the facilitation of tax evasion are up to date. The company expects those organisations that it works for and that work for it to demonstrate similar commitment and to have or to be implementing appropriate policies to support that commitment.

Diafora has a similar commitment to ensuring that it, the organisations it works for and that work for it do not engage in Modern Slavery. Diafora’s current Transparency Statement on Modern Slavery has been reviewed by the Board and signed by a Director.

Modern Slavery Act 2015 Policy and Statement:

Diafora Limited Policy.

  1. Diafora Limited (Diafora) is an International specialist consultant to the Construction Industry.
  2. Diafora is committed to the highest level of ethical standards and sound governance arrangements and sets high standards of impartiality, integrity and objectivity in relation to the conduct of its activities.
  3. Diafora adopts zero tolerance to corruption and bribery and this policy is endorsed by the Company Board.
  4. We fully support the government’s objectives to eradicate modern slavery and human trafficking.
  5. Our annual statement will provide information to supplement this policy, including details of our activities and supply chains and actions we are taking to support government.
  6. We expect all organisations we engage with to influence their global supply chains by improving transparency and accountability; and in so doing we can support the eradication of the injustice and brutality of modern slavery and human trafficking.

Phillip Holden – Managing Director 26th June 2018

 

Diafora Limited – Slavery and Human Trafficking Statement 2018/19

  1. Diafora Limited (Diafora) is an International specialist consultant to the Construction Industry
  2. We engage with a large number of private sector organisations in the conduct of our commercial activity
  3. Our activities are undertaken at arms-length and may take place in a number of countries around the world. Our principle suppliers are providers of office space, travel service providers and sundry support services to our business.
  4. Our clients are generally private and public Construction businesses and local authorities or developers.

Supply chain policy

  1. Our procurement activities take place around the world but are overseen from the Company headquarters in the UK. The profile of procurement as set out above means that the risk profile in relation to modern slavery of our supply chain is assessed as being very low
  2. We expect our Delivery Partners, organisations within our Frameworks and other companies we engage with to ensure their goods, materials and labour-related supply chains:

(i) Fully comply with the Modern Slavery Act 2015; and are

(ii) Transparent, accountable and auditable; and are

(iii) Free from ethical ambiguities.

  1. Through this statement we encourage Delivery Partners, organisations within our Frameworks and other companies we engage with to read and apply as appropriate ‘Advancing Responsible Business Practices in Land, Construction and Real Estate Use and Investment’, a joint publication between the United Nations Global Compact and the RICS.
  2. Individuals with evidence of non-compliance with the Modern Slavery Act in connection with Diafora supply chains are encouraged to report their concerns to senior management or use the national reporting service.

Steps taken by Diafora or underway.

(A) Management responsibility and general awareness. We have:

  • Agreed management responsibility for this policy and statement and received unanimous endorsement from our Executive Management Team and our Board.

We are:

  • Raising general organisational awareness by circulating an article to all staff explaining the requirements of the Act.

(B) Risk assessment. We have:

  • Undertaken an assessment to determine our risk exposure.
  • Established that our primary risk is association with a Supplier or Client with an ambiguous or non-compliant supply chain.
  • Included the Modern Slavery Act 2015 within our Risk Register to ensure the risk continues to be flagged, assessed and appropriately addressed.

(C) Risk mitigation. We are:

  • amending client and supplier standard terms and conditions to include a clause for breach in the event that a client has been convicted of an offence under section 1, 2 or 4 of the Modern Slavery Act 2015.

Steps to take 

(A) Management responsibility and general awareness. We will:

  • Report progress to our Executive Management Team and our Board.
  • Raise awareness of this published statement
  • Prepare the second annual statement next due 26th June 2019.

(B) Risk assessment. We will:

  • Commence a review exercise of this policy against our activities to establish whether the approach we have taken follows emerging best practice by:
  • Assessing and interpreting any recent or emerging case law and best practice; and
  • Benchmarking our activities against statements   and   action   plans undertaken by similar private organisations.
  • Re-evaluating the risk of non-compliance as part of our cyclical Compliance Risk Register assessment.

(C) Risk mitigation. We will:

  • Act promptly where a compliance breach has been identified or flagged.
  • Continue to feed-back lessons learnt into the compliance risk management process.

 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Diafora’s slavery and human trafficking statement for the financial year ending 26th June 2019.