Modern Slavery Policy

Introduction

This statement is made in accordance with the UK Modern Slavery Act 2015 and the United Nations Sustainable Development Goals (SDG’s) relevant to addressing trafficking in persons, and is published on behalf of Dual Inventive B.V. This statement refers to the financial year ending 31 December 2024 and sets out the steps we have taken to address modern slavery risks in our business and supply chains.

Dual Inventive B.V. recognises that it has a responsibility to take a robust approach to slavery and human trafficking. Dual Inventive B.V. is committed to preventing slavery and human trafficking in its corporate activities and ensuring that its supply chains are free from slavery and human trafficking.

In this statement, “Dual Inventive” refers to all Dual Inventive B.V. entities. The Annex contains a list of Dual Inventive B.V. entities.

Our organisation

Dual Inventive is specialised in designing and manufacturing SIL-4 technological products for enhancing safety and efficiency in railway infrastructure work, optimising available rail path capacity, and bolstering the reliability of the railway network.

Dual Inventive’s products can be divided into two categories: Safety products to improve the conditions of those working on or near the railway infrastructure and sensing products to monitor the railway infrastructure. All Dual Inventive’s equipment is connected to the (own proprietary) SIL-4 rated cloud platform: MTinfo 3000. The platform facilitates secure data transmission and streamlines equipment control and monitoring. Customers include railway contractors and railway infrastructure managers in the UK, France, the Netherlands, Belgium, and Australia.

We directly employ approximately 71 people, the majority of whom are based within the UK, Netherlands and Belgium. We also have contractors providing services to us from France, and Sri Lanka. The roles undertaken within our business are a mixture of managerial or office-based employees, developers, engineers and servicing technicians, mobile sales and operations teams and associated roles.

Assessment of modern slavery risk

To manage and minimise the risk of any future human slavery or forced labour situations occurring in our direct workforce or supply chain, we closely scrutinize our business activities and educate ourselves as to what steps we need to take to ensure we continue to operate in an ethical, compliant and humanitarian manner. An annual risk analysis will be conducted and, if necessary, preventive measures will be implemented to commit to our Modern Slavery statement.

When assessing our supply chain, we focus on the suppliers of Dual Inventive Production B.V. (hereafter: “Production”), as most purchases originate from that department. Within the Production entity, our focus is on key suppliers, as they are responsible for nearly all parts within the chain.

Our supply chain

Production is responsible for the supply chain (purchase, assembly, production, and delivery) of the Dual Inventive products, services, and parts. These items are delivered by Production to other Dual Inventive entities (see Annex).

Production selected ‘key suppliers’ for essential products, services, and parts. These companies are regularly used by Dual Inventive to deliver a key product, service, or part.

The purchase, manufacturing and assembly of our products and parts is partly outsourced to independent Dutch production partners to ensure redundancy. Cooperation with these partners is according to ISO 9001 quality procedure:

• Collaboration agreement (way of work/process, Service Level Agreement, risk management)
• Periodical operational meeting
• Periodical evaluation
• External audit (based on process and agreement)

The Co-operatives UK’s Modern Slavery Toolkit is used to identify our business risk areas and take steps to prevent modern slavery within the supply chain. (https://www.uk.coop/sites/default/files/2020-11/Toolkit%20Guide%20to%20modern%20slavery.pdf)

To identify our business risk areas, the following factors are considered:

• Industries that are indicated as high-risk areas for modern slavery because they involve high levels of low paid, dangerous, or temporary work.
• Goods or raw materials listed as high-risk by Anti-Slavery International (www.antislavery.org).
• Goods produced in countries indicated as having the highest number victims of modern slavery worldwide by The Global Slavery Index (www.globalslaveryindex.org).
• Category of workers where work is temporary, low skilled or high risk.

We work with some key suppliers that purchase goods in a country with a heightened risk of modern slavery. We currently have no identified actual or potential incidences of modern slavery or labour exploitation in our supply chain.

To prevent modern slavery in the supply chain, we take the following steps:

We keep a proper level of supply chain visibility
For our key suppliers an evaluation program is in place. Part of this program is a periodical evaluation and an external audit/visit.

We only engage with suppliers registered with The Netherlands Labour Authority which completes checks
All our key suppliers are based in the Netherlands. The Netherlands Labour Authority (Nederlandse Arbeidsinspectie) forms part of the Ministry of Social Affairs and Employment (het ministerie van Sociale Zaken en Werkgelegenheid). The Netherlands Labour Authority (NLA) works for fair, healthy, and safe working conditions and socio-economic security for everyone. The Netherlands Labour Authority checks if employers and employees comply with the various laws, decrees, and regulations in the field of labour. The Labour Authority also investigates fraud, exploitation, and organised crime within the chain of work and income. In the field of Social Affairs and Employment, she monitors developments and risks and reports them to the stakeholders.

Our people

We currently have not identified actual or potential incidences of modern slavery or labour exploitation in our people activities.

As regards our people, we currently implement the following actions:

We respect Human Rights
Wherever we work in the world, we commit to respect and uphold the fundamental human rights and freedoms of everyone who works for us and with us.  We will never knowingly cause or contribute to any activity or relationship which violates human rights, either directly or indirectly, and we will immediately address adverse human rights impacts if they occur.  We will never knowingly use or work with anyone who uses forced, compulsory, illegal or child labour.  As part of this, we have zero tolerance for any form of human trafficking. If we work with anyone who we discover is contravening our commitment to human rights, or has done so in the past, we will take  appropriate action, which may include ending the relationship and reporting the abuse to the appropriate authorities. We will ensure we comply with any restrictions and safeguarding requirements on employment of Young People within the territories where we operate.

We are inclusive and embrace diversity
Through our local Equality, Diversity, and Inclusion Policies we promote an inclusive culture of sensitivity and respect for differences in which everyone has the opportunity to flourish, make a difference and realise their full potential. Our success depends upon us accessing a diversity of talent and guided by our local Recruitment and Training Policies, we make decisions regarding hiring, development and promotion based on individual capabilities in relation to the needs of the business. We aim to provide equal opportunities to all our employees and applicants and do not tolerate any form of discrimination, including where characteristics are protected by law, and we encourage everyone to recognise and challenge discriminatory behaviour.

We carry out appropriate screening for our new employees
All new employees are carefully vetted using required local screening procedures, including, where appropriate, right to work checks for the territory in which they will work.

We offer fair reward and recognition
We operate fair and transparent reward and recognition processes that are supportive of employment rights, development, and fair wages.  We will always pay at least the minimum wage or, in the absence of a local threshold, a fair representation of the prevailing sector wage.  We will also comply with the laws on working hours, fair wages and payment practices in the countries in which we operate. All our employees are also paid through the company’s payroll systems via bank transfers (BACS/SEPA) and we do not support any other mechanism of wage payment.

We do not tolerate harassment or bullying
Our People strategy assists to ensure that we treat all colleagues with respect and in a professional and compliant way. This strategy includes our local guidance on Standards of Behaviour, and policies on Bullying, Harassment and Discrimination. We are committed to maintaining a workplace that is free from harassment and where all our people feel comfortable coming to work.  We prohibit any behaviour or conduct that may constitute harassment or bullying and expect our business partners and third parties to share this commitment.

We recognise the importance of employee health and wellbeing
We provide safe workplaces for our employees and comply with applicable health and safety laws in each of the countries in which we operate. Within our territories we also have in place various employee health and wellbeing initiatives, including a comprehensive Employee Assistance Programme, engagement calendar of health and wellbeing initiatives and a Health Surveillance programme.

We provide clear ways for our people to speak up and raise concerns
It is important to us that our people feel confident and safe in raising ideas, questions, and concerns. Our local Whistleblowing & Grievance Policies and “confidante” procedures are designed to make it easy for employees to make disclosures, without fear of retaliation. We encourage all our employees to report any concerns related to the direct activities of our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.

Aims for 2025

• Evidence of commitment to preventing modern slavery
  Key suppliers purchasing goods in a country with a heightened risk of modern slavery will be requested to provide evidence of their commitment to preventing modern slavery, either through correspondence or contractual agreements, along with an explanation of the steps they are taking to ensure that their supply chains are slavery free.
• Incorporate preventing modern slavery into our integrated management system
  We will conduct a risk assessment of modern slavery with key suppliers as part of our annual management cycle in our integrated management system.
• Supply of People via Agencies
  We expect all the agencies we use to comply with relevant local employment law/practices. We want to continue to form long-term relationships with these agencies so we can improve our understanding of their businesses to identify and mitigate modern slavery risks. We understand the value in furthering our understanding about how agencies recruit their staff, including any practices they may have for recruiting people from overseas to work in our territories. Our expectation is that the agencies we use are bound by our terms and conditions. We expect our recruitment agencies to be in effect an extension of ourselves, displaying our values and behaviours.

In 2025 we intend to carry out comprehensive due diligence audits of the recruitment agencies we use to better understand how and where they source their labour from, to properly test their compliance with local employment laws and to require them to sign up to a Supplier Code of Conduct.

• Training
  We intend to commence a Group-wide training programme to raise awareness and highlight the issue of modern slavery to our employees, starting with those most involved in Procurement and Recruitment activities but flowing out to include general awareness training for all our people, likely via an e-learning route.  We will also include this training within our standard Group inductions for new employees.

Our training will aim to enable employees to:

• Define Modern Slavery
• Recognise the types of individuals who might be at risk of becoming a victim of modern slavery
• Identify the warning signs of someone who is a victim of modern slavery
• Know where to signpost individuals to for help and support

We will also continue to strengthen employee awareness of our stance on slavery and human trafficking through articles on our internal communications channels.

• Group Policies
  Where possible, we will review our local people policies, including those on:
  • Equality, Diversity and Inclusion
  • Recruitment
  • Standards of Behaviour
  • Bullying, Discrimination and Harassment
  • Anti Bribery and Corruption
  • Whistle Blowing.

We will bring these policies together under an umbrella of Group Policies. This will enable us to monitor awareness, standards, consistency, and compliance more effectively across all our business entities.

• Employee Health and Wellbeing
  We intend to look at opportunities for alignment of health and wellbeing activities across Group (i.e. we will look at the feasibility of providing an international EAP service) to allow us to better monitor our performance in that area and deliver cost-effective solutions to promote engagement, employee voice and a positive workplace culture.

 Approval process

This statement has been approved by Dual Inventive’s Managing Director, who will review and update it annually.

Oisterwijk, 1 January 2025

Jacob Zeeman
Managing Director

Annex

This statement applies to Dual Inventive B.V. The following entities are included in this statement:

Dual Inventive Production B.V.
Dual Inventive Technology Centre B.V.
Dual Inventive Europe B.V.
Dual Inventive Ltd.
Dual Inventive Nederland B.V.
Dual Inventive Deutschland B.V.
Dual Inventive Belgique B.V.
Dual Inventive France B.V.