DMI’s Modern Slavery Act Statement for Fiscal Year 2020

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 subsidiaries in the UK, Canada, Spain, Germany, Italy, India, Japan, Argentina and Chile. The DMI group of companies is a global technology solutions enterprise that specializes in digital strategy, design, transformation and support. DMI utilizes expertise from multiple competencies in the areas of AI & Analytics, Commerce, Experience, Managed Services, IoT & Edge Computing, Cloud, Applications & Platforms, Cybersecurity and Government, delivering intelligent digital transformation solutions to commercial companies, government customers and other organizations.

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 global 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. DMI’s Policy Against Trafficking in Persons and Slavery (“Anti-Trafficking 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.

Additionally, DMI’s Code of Ethics and Business Conduct Policy (the “Code of Conduct”) establishes and affirms the basic principles and guidelines for officers, managers, and employees to assist in conducting DMI’s business in accordance with laws, regulations, and principals of ethical behavior. DMI complies with all applicable U.S. laws and those of other countries where DMI engages in business. Compliance with public law is vital to DMI’s continuation of current, and award of new, contracts. Even when there is no law, rule, regulation, or contractual provision covering a given situation, DMI expects employees to use common sense and sound judgment, and conduct themselves in an ethical manner.

DMI employees are trained and annually acknowledge they will uphold our Anti-Trafficking Policy and Code of Conduct.

Supplier Due Diligence

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.

Our Purchase Order Standard Terms and Conditions and agreement templates incorporate anti-human trafficking language for all subcontracts awarded in support of U.S. Federal work and all subcontracts entered into with commercial vendors.

Reporting

DMI’s Code of Conduct as well as our Anti-Trafficking Policy enable and encourage all employees to report any concerns, any violations, or potential violations of such policies, 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 the anti-trafficking requirements in their contracts and/or are found to have been involved in slavery or human trafficking.

Training & Awareness

All employees will submit annual certifications stating that they have reviewed and acknowledged DMI’s Code of Conduct and Anti-Trafficking Policy. All 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 2020, as approved by the Board on May 21, 2021.

Signed on the Board’s behalf by:

Jay Sunny Bajaj
Director

Michael Altshuler
Director