Modern Slavery & Human Trafficking Statement

The Dialectica Group (the “Group”) is an information services company that brings real-time insights to the world’s top business professionals with the vision to shape better business decision making worldwide.

The Group has a zero-tolerance approach to any form of modern slavery, forced labour or human trafficking in any part of its business or supply chain. We are devoted to acting with quality and transparency in all our business dealings and maintaining high ethical standards, protecting human rights and acting with honesty and integrity in everything we do.

Our Group Structure

The Group is headquartered in the UK and comprises Dialectica Group Holdings Ltd, which acts as the ultimate parent company of the Group, and Dialectica Ltd, the parent company of the Group, alongside its subsidiaries, Dialectica Advanced Technologies, ENS Solutions, Dialectica Canada, Dialectica USA, Dialectica Vietnam, and Dialectica Colombia. This statement therefore covers actions taken in relation to the Group.

Our Values

The Group opposes all forms of slavery which consists of but is not limited to human and drug trafficking, and forced, unpaid and child labour.

Our mission and actions reflect a drive to eradicate modern slavery in commercial organisations within our supply chain. As an ethically driven company, we conduct all business with integrity, having a zero-tolerance approach to modern slavery and human trafficking risks.

Our Policies

Dialectica’s commitment to respecting human rights in the workplace is embedded within the Group’s Employment Handbook, Code of Conduct and Discrimination and Harassment Policy.

Dialectica’s policies are approved by the management board and ensure that there is transparency in the Group’s business and demonstrate our commitment to ensuring modern slavery does not form part of the business and its supply chain.

Employment Handbook & Code of Conduct

For Dialectica, it is of utmost importance to ensure that the people who support our business are treated with fundamental dignity and respect to ensure a safe, fair, and inclusive environment for all.

The basic principles that are safeguarded in Dialectica’s Code of Conduct are:

Equal opportunity to attain and maintain all aspects of employment that are not susceptible to any forms of discrimination.

Respect in the workplace with zero tolerance to any threats of violence, insubordination, discriminatory jokes and language, personal insults -especially those using racist or sexist terms- unwelcome attention, harassment, advocating for, or encouraging, any of the above behavior.

Discrimination and harassment is not acceptable in our workplace and we are committed to providing a work environment free from physical, sexual, or psychological harassment, discrimination and physical or verbal abuse.

Professionalism and integrity through respecting all stakeholders and abstaining from any abuse of authority.

In addition, the Group has procedures in place pertaining to its employment practices:

• Recruitment processes in line with local labour laws, including ‘right to work’ document checks, contracts of employment, and checks to ensure all employees are above the minimum working age.
• Employees are made aware of their employment terms and conditions through a variety of channels including but not limited to written employment contracts, employee handbooks, and internal communications.
• Market-related pay and rewards, which are reviewed regularly and linked to relevant benchmarks.
• A complaint handling procedure is in place to support employees who allege harassment, violence, discrimination, inappropriate behaviour by a supervisor or co-worker, or other behaviours that are contrary to Dialectica’s values and commitment. The reporting and investigating process is designed to ensure that every issue reported is treated fairly, promptly, thoroughly and with the utmost confidentiality.
• A Diversity, Equity & Incentive Steering Committee has been established, which is actively engaged in all DE&I initiatives. The Committee holds a meeting quarterly or ad hoc, if a DE&I urgent matter arises. Dialectica has also developed an Inclusive Language and Communication Guide.
  

Discrimination and Harassment Policy

Dialectica has a zero-tolerance policy when it comes to discrimination and harassment in the workplace and is committed to providing a work environment free from physical, sexual, or psychological harassment, discrimination and physical or verbal abuse. Dialectica’s employees must not be subject to discrimination based on, but not limited to, non-job-related characteristics such as: race, color, age, gender, sexual orientation, gender identity or expression, sex, religion, ancestry, citizenship, national origin, disability, medical condition, genetic characteristic or information, creed, marital status, family status, pregnancy, or other legally protected status.

All Dialectica employees are entitled to a workplace that respects their fundamental rights, such as inviolability of the person, respect for their name, reputation and privacy. That is why all employees must contribute to a harmonious work environment free of any form of incivility, violence, discrimination, or harassment; in particular by adopting behaviours that promote respect, cooperation, politeness, courtesy and good manners in their work relations.

Suppliers Due Diligence

At Dialectica, we establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. It is therefore our intention to only contract with third parties who can satisfy our internal standards with regards to employment and welfare conditions.

We firmly believe that the risks of modern slavery and human trafficking in our supply chain are low, but we remain vigilant in respect of new and existing suppliers. We make little use of services demanding unskilled labor, and those services and products we do use are sourced from reputable suppliers. Our suppliers are for the most part limited to professional services, commercial real estate, staff benefits and healthcare, facility management, office equipment and computer hardware and software.

To help identify and monitor the risk of slavery and human trafficking in our supply chain we conduct pre-contracting due diligence and ongoing due diligence on third parties taking into account the following risk factors:

• The country the third-party operates in (and has supply chains in);
• The sector the third-party operates in; and
• The products produced, manufactured or supplied by the third party.

In addition, in case we identify instances of breach of the modern slavery provisions, Dialectica shall immediately terminate its relationship with suppliers and other individuals working on its behalf.

Our Commitments

We’re always looking for ways to improve our modern slavery and human trafficking controls in the workplace and in the way we work with third parties. To that end, in FY2025 we will focus on the following:

• Introducing a Third-Party Code of Conduct which will be shared with third parties at onboarding as well as periodically across the lifecycle of the relationship and which the third party should acknowledge; and
• Ameliorating the process of escalating concerns.

This statement is published in accordance with section 54 of the Act and relates to the financial year January 2024 to December 2024. It was approved by the board of directors on 20 December 2024.

Name: Fred Corkett

Title: Director

Date: 20/12/2024

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