DMI’s Modern Slavery Statement

DMI’s Modern Slavery Statement for Fiscal Year 2018

About DMI

DMI is the world’s first integrated end-to-end mobility company. Digital Mobile Innovations Limited (DMI UK) is a member of the DMI group of companies (DMI), which are headquartered in the United States and have offices in the UK, Canada, Spain, Germany, India, and Cambodia. The DMI companies, including DMI UK, offer information technology and business strategy solutions to commercial and government customers around the world, with particular emphasis on mobile enterprise solutions. DMI UK’s service offerings include Mobile Services, Digital Strategy, Brand Marketing and Customer Experience, IoT and Analytics, Artificial Intelligence, and Enterprise Application Services.

DMI employs over 2,000 people globally and works with numerous suppliers in the UK and across Europe.

Respect, integrity, dignity, trust, and fairness are the core values that guide us as individuals and as a business. We demonstrate high ethical standards and high regard for the law and professional business conduct in our interactions with customers, employees, suppliers, partners, and the community. Our company standards and values are key to the way we collaborate with our suppliers. We manage our own operations and supply chain through effective due diligence, risk assessment, training and collaboration with suppliers to ensure we help protect vulnerable groups of people.

Policies

DMI is committed to enforcing a workforce and supply chain free of human trafficking and all forms of forced labor and unlawful labor. As a global organization, we have a zero tolerance policy surrounding modern slavery, which encompasses human trafficking, servitude, and forced labor. This policy is consistent with our core values and supports our compliance with the Modern Slavery Act 2015 and all U.S. Government regulations regarding slavery, forced labor, and trafficking in persons. In compliance with these laws, DMI employees are trained and annually acknowledge they will uphold our Code of Ethics and Business Conduct.

Supplier Due Diligence

In compliance with DMI’s Policy Against Trafficking in Persons and Slavery and, by extension, the Modern Slavery Act 2015, Corporate Quality Assurance representatives perform independent reviews and/or audits to ensure procurement process compliance with U.S. Federal regulations. Our U.S. Federal vendors annually certify their compliance with the Supplier Representations and Certifications document, which includes compliance with laws on human trafficking and slavery in the country or countries in which the vendors do business. The Combating Trafficking in Persons clauses in U.S. Federal Acquisition Regulation 52.222-50 are incorporated into DMI subcontracts, as required, when doing business on behalf of U.S. Federal customers.

In 2019, DMI will update our Purchase Order Standard Terms and Conditions and agreement templates to incorporate anti-human trafficking language for all subcontracts awarded in support of U.S. Federal work.

Reporting

DMI has established a formal policy that enables and encourages all employees to report any concerns, any violations, or potential violations of this policy, without fear of retaliation, to the employee’s supervisor, another member of management, DMI Security, or to Human Resources.

DMI follows the Investigative Procedures found within the Employee Handbook located on DMI’s intranet website. Once a complaint is received, DMI will conduct a prompt and thorough investigation. The investigation may include interviews with all involved employees and any employees who are aware of facts or incidents alleged to have occurred. Once the investigation is completed, a determination will be made regarding the validity of the allegations. If it is determined that a violation has occurred; prompt, remedial action will be taken.

Violations by employees will result in disciplinary actions up to and including termination of employment. In addition, DMI may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in slavery or human trafficking.

Training & Awareness

All employees will submit annual certifications stating that they understand, will comply with, and have complied with DMI’s Policy Against Trafficking in Persons and Slavery. Copies of all signed certifications will be maintained by the Human Resources Department.

About this statement

This statement is made on behalf of the DMI group of companies by Digital Mobile Innovations Limited pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes DMI’s slavery and human trafficking statement for the financial year ending 31 December 2018, as approved by the Board on April 12, 2019.

Signed on the Board’s behalf by:
JAY SUNNY BAJAJ
Director

NOAH ASHER
Director

MICHAEL ERIKSSON
Director

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