Modern Slavery Statement

The following statement has been published in accordance with d-fine’s responsibilities under Section 54 of the Modern Slavery Act 2015. It describes the steps d-fine has taken against slavery and human trafficking during the year ending 30 June 2019.

In this statement “d-fine” refers to the activities of d-fine Ltd (UK), d-fine GmbH (Germany), d-fine Austria GmbH (Austria) and d-fine AG (Switzerland).

Business Overview

d-fine is a European consulting firm which, by means of scientifically-minded employees, provides innovative and future-proof solutions through sustainable technological implementation.

Our highly qualified employees and extensive practical experience enables us to develop bespoke, future-proof solutions for our clients’ tasks and to implement these efficiently. The typical integrated d fine approach − design and implementation under one roof – is a core component of our project work.

d-fine places a strong emphasis on fairness and collaboration with respect to its employees, clients and business partners. Moreover, the success of our projects is rooted in the close and trusting relationships we have with our clients and suppliers.

Policies

d-fine pursues a sustainability strategy with a long-term focus. This strategy is reflected in all aspects of our activities and in our interaction with clients, employees, suppliers, environment, and society. We are committed to minimise the potential negative social and ecological impact of our business activities.

This strategy lead to the implementation of a d-fine Sustainability Guideline and a d-fine Code of Conduct. Together they cover the steps taken to ensure environmental and climate protection, fair working conditions, prevention of child labour, and the fight against corruption in our company. They express our zero tolerance towards slavery, human trafficking, and corruption and include measures to prevent them.

The d-fine Sustainability Guideline and the d-fine Code of Conduct have been continually improved and extended.

Overall responsibility for sustainable and responsible business activities lies with d-fine’s Managing Directors. A sustainability report and the review of all aspects of sustainability are produced by the d fine Compliance Board. For the maintenance of the d-fine Sustainability Guideline, the review of the relevant key performance indicators and the update of the sustainability report, the board receives assistance from other employees.

d-fine Operations

Our services are provided by our own employees, with the majority provisioned in the UK, EU, and Switzerland. To a limited degree, d-fine consultants work on other international projects. Our internal standards, which comply with the comprehensive legal requirements in the UK, EU, and Switzerland, apply to all our employees irrespective of project location. Since we exclusively employ highly qualified employees, long-term staff retention can only be achieved through fair working conditions and remuneration, a wide range of external professional development opportunities, and other employment benefits and measures, which far exceed minimum legal requirements.

Supply Chain

Since we are a professional service provider, the depth of our value chain is low. Our services are almost exclusively provided by our own permanent employees and not by temporary staff. We do not produce physical goods. Material resources are only used to a limited extent in our work. We require technical equipment such as laptops and mobile phones and resources for the operation of our offices (amongst others electricity, heating, water, office supplies).

The sustainable procurement of technical equipment poses a particular challenge, since compliance with standards and fair working practices in these industries is not consistently guaranteed and difficult to verify. Therefore, we are in continuous exchange with the two main suppliers from whom we procure laptops and mobile phones. Both are among our five largest suppliers and have put in place targeted measures to prevent human trafficking and modern slavery in their supply chains and to implement fair working practices at their suppliers. Reports on these practices are published on a regular basis.

We are aware of the social and ecological impacts of our business activities and continually strive to minimise these. To this end, we have carried out screening of our suppliers. Several suppliers provided evidence of their compliance with international human rights standards. We procure many of our goods and services from small local suppliers. Due to their size, most of these suppliers do not have internationally recognised certifications or other formal evidence of their compliance with human rights standards. However, these suppliers are almost exclusively based in the UK, EU, or Switzerland and are, thus, subject to stringent human rights and sustainability standards and to strict regulations prohibiting slavery and human trafficking.

Risk Assessment

Based on the nature of our supply chain and of our operations, we consider the risk of modern slavery and human trafficking posed by our activities to be low. Risks may arise from our supply chain, in particular the providers of technical equipment and certain local suppliers such as cleaning companies.

Steps taken during the financial year

During the last financial year ending 30 June 2019, d-fine published a declaration of compliance with the German Sustainability Code. The declaration contains a detailed analysis of the social and ecological impacts of our activities and presents the measures in place to mitigate such negative effects. We aim to review on an annual basis the declaration of compliance and to document our engagement, not least with respect to the fight against slavery and human trafficking. Furthermore, we have updated our Sustainability Guideline and our Code of Conduct.

Approval

This statement was approved by the d-fine Board of Directors and signed on their behalf by Wolfgang Pleyer, Director of d-fine Ltd and Managing Director of d-fine GmbH.

London, July 2019