Door is committed to improving our practices to combat slavery and human trafficking. We take seriously our responsibility in the protection of fundamental human rights and the elimination of modern slavery by ensuring that slavery, human trafficking and child labour has no place anywhere in our business. We promote a safe and happy workplace where we recruit and celebrate a diverse workforce and our colleagues feel valued as individuals, with equal opportunities.
Modern slavery is a crime and a gross violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Door has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
Door is also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015 (Act). We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
This Anti-Slavery and Human Trafficking Policy (Policy) applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
This Policy does not form part of any employee’s contract of employment and we may amend it at any time.
We are a SaaS company and Door Ventures, Inc has an office in Sparks, Maryland, USA, Door Ventures Limited is a wholly-owned subsidiary and has offices in London and Liverpool, UK.
We have a zero-tolerance policy towards modern slavery, a crime and violation of fundamental human rights: This includes any form of slavery, servitude and forced or compulsory labour.
We are committed to working ethically and with integrity in all our business relationships and to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
This Anti-Slavery and Human Trafficking Policy highlights our commitments in our dealings and relationships, including our own recruitment process and our supply chain. It also sets out steps that our staff can take if they are concerned about modern slavery.
Our zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
We expect all our contractors, suppliers and other business partners to adopt the same high standard as we do to prevent modern slavery, by ensuring all employees and workers are treated with dignity and respect in a fair and ethical environment.
To ensure all those in our supply chain and contractors comply with our ethics, we have in place a supply chain compliance programme which:
Under our supply chain compliance programme, suppliers are categorised according to the level of risk posed and an assessment will be made as to whether a plan of action is required to satisfy any gaps. We expect our suppliers to adopt the same principles when contracting with their own suppliers and plan to make this a requirement.
All suppliers are required to sign a declaration confirming their compliance with the Modern Slavery Act 2015 and our Anti-Slavery and Human Trafficking Policy and to contract on terms which ensure that we can check their adherence to these principles and where appropriate take corrective action.
We intend to implement an annual audit programme for major suppliers to ensure continued compliance with our obligations under the Modern Slavery Act 2015.
We are dedicated to maintaining a fair and ethical workplace for all our staff. We ensure compliance with all applicable employment legislation relating to employee recruitment and terms and conditions.
Training on this Policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
Door’ Co-Founders have overall responsibility for ensuring this Policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Operations Manager has primary and day-to-day responsibility for implementing this Policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this Policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. All persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners must read, understand and comply with this Policy and are required to avoid any activity that might lead to, or suggest, a breach of this Policy.
The Operations Manager must be notified as soon as possible if anyone believes or suspects that:
We encourage to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. We promote openness and will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.
Any employee who breaches this Policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this Policy.
This policy will be reviewed as it is deemed appropriate, but no less frequently than every 12 months.
Further information and advice on this policy can be obtained from the Door Team, policies@doorfunds.com.