Modern Slavery Policy
1. Purpose
This policy outlines Dunton’s commitment to preventing modern slavery, human
trafficking, forced labour, and related human rights violations in our operations and
supply chains. We align our approach with the VINCI Group’s principles and ethical
standards. For more information, please refer to VINCI’s Modern Slavery and Human
Trafficking Statement.
2. Scope
This policy applies to all employees, contractors, suppliers, and business partners
engaged in Dunton’s operations in compliance with the Modern Slavery Act 2015.
3. Commitment
Dunton is committed to:
3.1.Prohibiting forced labour, human trafficking, and any form of exploitation.
3.2.Ensuring fair recruitment practices, including prohibiting recruitment fees for
workers.
3.3.Respecting workers’ rights to freedom of movement and prohibiting the
withholding of personal documents.
3.4.Adhering to fair wages, safe working conditions, and reasonable working
hours.
3.5.Preventing child labour and ensuring compliance with minimum age
regulations.
3.6.Providing grievance mechanisms for workers to report any concerns related
to labour practices.
4. Due Diligence and Risk Management
4.1.To mitigate the risk of modern slavery, Dunton will:
4.1.1. Conduct due diligence on suppliers and subcontractors to ensure
compliance with ethical labour standards as per the Modern Slavery Act
2015.
4.1.2. Include contractual clauses prohibiting modern slavery in supplier
agreements.
4.1.3. Perform regular audits and site inspections where necessary.
4.1.4. Require training for relevant employees on identifying and preventing
modern slavery.
5. Reporting and Whistleblowing
Employees and stakeholders are encouraged to report any suspected cases of
modern slavery through our confidential reporting channels. No retaliation will be
taken against individuals who report in good faith. For more details on
whistleblowing, please refer to our Whistleblowing Policy.
6. Compliance and Continuous Improvement
6.1.As part of our commitment to compliance, we will:
6.1.1. Review and update this policy periodically to align with evolving legal
requirements and industry best practices.
6.1.2. Where necessary, collaborate with industry groups, NGOs, and
governmental bodies to enhance our approach to preventing modern
slavery
7. Right to Work Verification and Immigration Compliance
Dunton is committed to ensuring that all individuals engaged in our business have
the legal right to work in the United Kingdom and that all employment practices
comply with the Immigration, Asylum and Nationality Act 2006.
7.1.Identification and Verification of Workers
7.1.1. Prior to commencing employment, all prospective employees are
required to provide evidence of their right to work in the UK.
7.1.2. Dunton will identify whether workers are UK nationals or foreign
nationals through the right to work verification process and will maintain
records of nationality where legally permitted and necessary for
compliance purposes.
7.1.3. These checks apply equally to all potential employees, permanent
employees, temporary workers, seasonal workers, apprentices, and any
other individuals engaged by the business.
7.2.Compliance with Immigration Legislation
7.2.1. Dunton maintains documented procedures and controls designed to
ensure compliance with Sections 15 to 25 of the Immigration, Asylum and
Nationality Act 2006
7.2.2. Right to work checks will be completed before employment commences
and in accordance with current Home Office guidance.
7.2.3. Managers responsible for recruitment will receive appropriate training
concerning right to work requirements and acceptable documentation.
7.3.Acceptable Documentation
7.3.1. Documents used to verify an individual’s right to work may include
passports, birth certificates, immigration status documents, National
Insurance evidence, digital immigration status checks, or other
documents specified by the Home Office.
7.3.2. All verification activities will be conducted in accordance with current
Home Office Right to Work guidance and statutory excuse requirements.
7.4.Record Retention
7.4.1. Copies of all documents used to verify an individual’s right to work will
be securely retained for the duration of employment and for a minimum of
two years following the end of employment.
7.4.2. Records will be stored and managed in accordance with data protection
legislation.
7.5.Agency, Self-Employed and Subcontracted Workers
7.5.1. Where labour is provided through agencies, subcontractors, selfemployed personnel, or other third parties, Dunton will require
confirmation that appropriate right to work checks have been completed.
7.5.2. Suppliers, labour providers and subcontractors may be required to
provide evidence of their processes and compliance upon request.
7.5.3. Right to work compliance requirements will be incorporated into
supplier and subcontractor due diligence processes.
7.6.Ongoing Monitoring and Repeat Checks
7.6.1. Where an individual’s right to work is time-limited, Dunton will conduct
follow-up checks before the expiry of the relevant permission.
7.6.2. Periodic reviews may be undertaken to ensure ongoing compliance
across all categories of workers, including agency workers, temporary
workers and seasonal personnel.
7.6.3. Any concerns regarding immigration status or right to work eligibility will
be investigated promptly and appropriate action taken where necessary.
8. Accountability
Failure to comply with this policy may result in disciplinary action, contract
termination, or legal proceedings where applicable.
9. Employee Acknowledgement:
I confirm I have read and understood this policy.
Employee Signature: ______________________ Date: ___ / ___ / ______
9. Policy Approval & Review Date
Approved By: Dannyjo Cox, Managing Director
Approval Date: 11 August 2026
Next Review Date: 11 August 2027
Version: 2.0
