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Modern Slavery

DSW Capital PLC has taken steps to ensure that slavery and human trafficking are not taking place in our supply chains or any part of our business. This statement relates to DSW Capital PLC and its subsidiaries, DSW Services LLP and DSW Operations Limited, known collectively throughout this document as ‘DSW’.

In accordance with the Modern Slavery Act 2015, this statement sets out the steps that DSW has taken to ensure that slavery and human trafficking are not taking place in our supply chains or any part of our business. This statement is in respect of DSW’s financial year ended 31 March 2024 and was approved by the DSW Board of Directors on 24 June 2024.

Overview

DSW has decided to voluntarily publish an annual modern slavery statement and provide greater transparency on the measures we are taking to prevent exploitation in our operations and
supply chains. As an organisation, we are committed to valuing human rights, championing equality and challenging discrimination. We take our role seriously in taking a robust approach to the global problem of slavery and human trafficking.

Our organisational structure and supply chains

DSW Capital PLC is a public company incorporated and domiciled in England and Wales. The principal activity of DSW Capital and its subsidiaries, DSW Services LLP and DSW Operations
Limited is the licensing of the DSW brand and associated brand names for use in the professional services sector. On 31 March 2024, the DSW Network included 25 licensee businesses across 11 offices in the UK. Each licensee business is a separate legal entity, and DSW Capital is not responsible for the services or activities of these businesses. However, DSW Capital does set
clear expectations within the legal agreements, Code of Conduct and Partner Charter to ensure that procedures are in place to address the modern slavery risk in our licensee businesses.

Our business uses professionally qualified people employed directly by DSW. Our policies ensure fair treatment of all employees. Our external suppliers are UK-based companies in low-risk
sectors, such as professional services, IT, PR, conference and venue suppliers and training providers.

Our policies in relation to slavery and human trafficking

DSW Capital PLC has a zero-tolerance position on violations of the UK’s anti-human trafficking and anti-modern slavery laws.

We seek to treat everyone fairly and consistently, creating a workplace and business environment that is open, transparent, and trusted. Our policies and procedures relating to the Modern Slavery Act align with our culture and values.

  • Our specific procedures to address modern slavery risk include:
  • An Anti-Bribery policy which allows our people to recognise and deal with incidents of bribery and corruption
  • A whistleblowing policy that ensures that all individuals can raise concerns internally and in a confidential manner
  • A whistleblowing hotline that allows for anonymous reports to be submitted by our employees
  • A Diversity and Inclusion policy that protects our employees from unfair treatment and promotes a fair and inclusive workplace
  • Robust recruitment processes in line with relevant employment laws
  • A network of Mental Health First Aiders to provide support and guidance to employees

Due diligence processes

Before a new licensee business joins the DSW network, a thorough due diligence process takes place to ensure that the firm has a good reputation with appropriate practices in a number of
areas, including people and culture. Once they join the DSW Network, compliance with DSW policies is a legal requirement.

Before a new supplier is contracted, consideration is given to their reputation, integrity, financial strength and compliance with legislation and best practice. If an existing or potential supplier were to be suspected of having links to involvement in modern slavery, our arrangements with them would immediately cease.

Risk Assessment and management

We are undertaking a risk assessment of our supply chains to ensure that the nature of the goods and services which we procure, the locations from which we procure them, and our procurement
practices means that the risk of human trafficking or slavery occurring in our business or our supply chains is low.

Notwithstanding this, we are committed to continual improvement in managing human rights and modern slavery risk in our supply chain. We will continue to review our policies and procedures and assess the risks within our business and supply chains regularly.

Key performance indicators to measure the effectiveness of steps being taken

We log complaints received via our whistleblowing hotline system or through other sources, together with the actions taken. To the date of this statement, DSW has had no identified instances of modern slavery.

Training on modern slavery and trafficking

DSW provides periodic training to all employees on the subject of modern slavery to ensure that they can recognise what modern slavery is, how they can take appropriate action to manage the
risks, raise questions and report concerns.