Policies, Terms and Conditions

Updated on 1 April 2026

 This Policy applies to all Disprz employees, officers, directors, contractors, consultants, agents, suppliers, business partners, and any third parties engaged in providing goods or services to or on behalf of Disprz globally. It covers all operations, including our supply chains, procurement activities, and business relationships. 

1. For the purposes of this Policy:
1. Modern Slavery includes slavery, servitude, forced or compulsory labor, debt bondage, human trafficking, and other forms of exploitation.
2. Supply Chain means all entities involved directly or indirectly in providing goods and services to Disprz.
3. These definitions are intended to cover recognized international standards on modern slavery and human trafficking.

1. Zero Tolerance: Disprz strictly prohibits modern slavery, forced labor, human trafficking, and related abuses in its own operations and throughout its supply chains.
2. Legal and Ethical Compliance: We comply with all applicable laws and international standards related to modern slavery and human trafficking in the jurisdictions where we operate.
3. Responsibility Across Relationships: Our employees, contractors, suppliers, and partners are expected to uphold the same standards and to operate transparently and ethically.

1. Executive Oversight: Ultimate responsibility for this Policy rests with senior leadership and the Board of Directors.
2. Operational Oversight: The Legal and Compliance team, in consultation with relevant business functions (including Procurement and HR), is responsible for implementation, monitoring, and reporting under this Policy.
3. Employee Responsibilities: All employees and representatives must understand and comply with this Policy and raise concerns when appropriate.

1. Supply Chain Risk Assessment: We conduct periodic risk assessments of our supply chain based on geography, industry sector, labor practices, and other indicators of modern slavery risk.
2. Supplier Screening: Prospective suppliers and business partners are screened before onboarding, including requirements to provide evidence of compliance with anti‑slavery standards.
3. Ongoing Monitoring: High‑risk suppliers may be subject to enhanced due diligence, site audits, compliance reporting, and follow‑up reviews.

 We provide regular training for employees in roles that present potential exposure to modern slavery risks (such as procurement, supply chain, and HR). Training includes how to recognize signs of modern slavery, obligations under this Policy, and how to report concerns. 

1. Encouraging Reports: Employees, contractors, suppliers, and supply chain workers are encouraged to report concerns related to modern slavery or human trafficking.
2. Confidential Mechanisms: Reports can be made confidentially through internal reporting channels, including directly to the Compliance team.
3. No Retaliation: Disprz strictly prohibits retaliation against anyone who reports in good faith or assists with an investigation.
4. Investigation and Action: All reported concerns will be promptly and thoroughly investigated, with corrective actions taken where appropriate, including supplier contract termination or referral to authorities.

1. All suppliers must affirm they do not engage in modern slavery practices and must comply with this Policy and applicable laws.
2. Supplier contracts will incorporate anti‑slavery and human trafficking clauses and may require periodic compliance attestations.
3. Where a supplier is found non‑compliant, Disprz will take appropriate action, potentially including suspension or termination of the relationship.

 In instances where modern slavery risks are identified, Disprz will seek to remediate harm where possible, including through engagement with the impacted parties, corrective action plans with suppliers, and collaboration with enforcement authorities or NGOs as applicable. The Company will document findings and actions taken to demonstrate responsiveness and continuous improvement. 

Disprz maintains records of risk assessments, supplier due diligence, training attendance, audit findings, and reports of potential violations. We are committed to transparency and may publish disclosures or reports relating to modern slavery in line with applicable legal obligations (such as those under the UK Modern Slavery Act where relevant). 

 This Policy will be reviewed at least annually and updated as necessary to remain aligned with legal developments, emerging best practices, and changes in our business operations or supply chain.