ANTI BRIBERY POLICY
04 JAN – 31 DEC 2022

Introduction

Dolphin values its reputation for ethical behaviour, financial probity and reliability. It recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. Its aim therefore is to limit its exposure to bribery by:

  • setting out a clear anti-bribery policy;
  • establishing and implementing anti-bribery procedures as appropriate;
  • communicating this policy and any relevant procedures to employees and to others who will perform services for the Company;
  • undertaking appropriate due diligence measures before engaging others to represent the Company in their business dealings;
  • monitoring and reviewing the risks and the effectiveness of any anti-bribery procedures that are in place;
  • prohibiting the offering, giving, solicitation or acceptance of any bribe (whether cash or other inducement).

This policy prohibits any inducement that results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action that may not be solely in the interests of the Company or of the person or body employing them or whom they represent.

This policy is not meant to prohibit normal and appropriate hospitality or the giving of a gift on a festival or at another special time, providing they are customary, proportionate, and properly recorded.

Inevitably, decisions as to what is acceptable may not always be easy. If you are in any doubt as to whether a potential act constitutes bribery, the matter should be referred to a director before proceeding.

Your responsibility

The prevention, detection, and reporting of bribery is the responsibility of all employees; and the Company is committed to:

  • encouraging you to be vigilant and report any suspicion of bribery;
  • providing you with suitable channels of communication and ensuring that sensitive information is treated appropriately;
  • investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution;
  • taking disciplinary action against any individual(s) involved in bribery. Any suspicion of bribery should be reported in confidence to the Managing Director, who has the overall responsibility for bribery prevention.

MODERN SLAVERY STATEMENT
04 JAN–31 DEC 2022

This statement applies to Dolphin Solutions Ltd (referred to in this statement as “we” or “Dolphin”).

Organisational Structure

Dolphin Solutions is a global leader in the washroom product supply. From dispensers to hot-air dryers, sensor taps and bins and baby change units, our expansive selection of washroom solutions are intelligently designed not just to look good but to be truly fit for purpose.

With the head office located in Bodiam, East Sussex, and another office in Milton Keynes, Herts, the company continues to grow and expand nationwide as well as internationally.

The business is led by a Senior Strategy Team.

The labour supplied to Dolphin in pursuance of its operation is carried out in locations nationwide, including two offices in Bodiam and Milton Keynes, as well as our showroom in London.

Definitions

Dolphin considers that modern slavery encompasses:

  1. human trafficking;
  2. forced work, through mental or physical threat;
  3. being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
  4. being dehumanised, treated as a commodity or being bought or sold as property;
  5. being physically constrained or to have restriction placed on freedom of movement.

Commitment

Dolphin acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015.

We understand that this requires an ongoing review of both our internal practices in relation to our labour force and, additionally, our supply chains.

Dolphin does not enter into business with any other organisation, in the United Kingdom or abroad, that knowingly supports or is found to involve itself in slavery, servitude, and forced or compulsory labour.

No labour provided to Dolphin in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking.

We strictly adhere to the minimum standards required in relation to our responsibilities under relevant employment legislation in the United Kingdom, and in many cases, exceed those minimums in relation to our employees.

Supply Chains

In order to fulfill its activities, Dolphin’s main supply chains include those related to the supply of raw plastic material and washroom goods from various suppliers in the United Kingdom, Europe, China, and Taiwan.

We understand that our first-tier suppliers may be intermediary traders and therefore have further contractual relationships with lower-tier suppliers.

Potential Exposure

Dolphin considers its main exposure to the risk of slavery and human trafficking to exist in its supply chains because they involve the provision of labour in countries where protection against breaches of human rights may be limited.

In general, we consider our exposure to slavery/human trafficking to be relatively limited.

Steps

Dolphin carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

We have not, to our knowledge, conducted any business with another organisation that has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, Dolphin is reviewing its supply chain management process to include:

  1. termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery;
  2. identification and assessment of potential risks in our supply chains;
  3. impact assessments of our services upon potential instances of slavery;
  4. action plans to address risk to modern slavery;
  5. a zero-tolerance policy towards modern slavery;
  6. any training needed for our team on modern slavery.

Policies

Dolphin has the following policies that further define our stance on modern slavery:

  1. Corporate Social Responsibility Policy;
  2. Supplier Code of Conduct;
  3. Equal Opportunities and Diversity Policy.