Modern Slavery Act

In DP World we believe firmly that the role we play in the communities where we operate, as an important employer worldwide, commits us to playing an active role in improving people´s lives, strengthening communities, and protecting the environment. This means that slavery, servitude, forced labor, and human trafficking are not tolerated in our operations or those of our providers globally.

Our Organization

DP World is a facilitator of global trade that comprises ports and terminals, Parks, logistics and economic zones together with maritime services. Our dedicated team of over 53,000 employees in 131 countries cultivates lasting relationships with governments, shipping lines, importers and exporters, communities, and many other important components of the global supply chain, to add value and offer quality services today and tomorrow.

Our policies and procedures on modern slavery and human trafficking

Our commitment of guaranteeing that there is no modern slavery or human trafficking in our business, and guaranteeing that our worldwide supply chains are also free from these problems is based on a variety of policies that are applied throughout the group.

The policy on modern slavery and human trafficking is reviewed annually, and establishes the focus of modern slavery and human trafficking both in DP World and with respect to our providers. The policy also clarifies the steps that the company's employees can take if they have concerns about the existence of incidents like these.

Other key policies that include provisions regarding modern slavery and human trafficking are:

• Policies and procedures for acquisitions, that establish minimum criteria that must appear in the list of DP World´s approved providers, including provisions regarding modern slavery, human trafficking, and child/forced labor.
• The company´s norms and policies for behavior and procedure which establish the obligation of employees to report suspicious incidents and known incidents involving modern slavery and human trafficking, how to do so, and the consequences of not doing it.
• Hiring and selection policies, that include the prohibition of the use of child labor and the withholding of original travel and identification documents issued by the government of the workers, unless the law so requires.

We have established a self evaluation of providers regarding modern slavery and human trafficking as part of our provider selection process; a code of conduct for providers; and the modern risk of slavery or human trafficking for potential providers is taken into account in our acquisition decisions.

In 2019, DP World became a signatory of the United Nations Global Convention (UNGC) and its 10 principles, which cover human rights, labor, the environment, and the fight against corruption. In signing the United Nations Global Convention, DP World committed itself to aligning its strategies and operations with these principles. An internal Working Group on Human Rights was established in DP World in 2019, to develop a framework for Human Rights and related policies and procedures for their implementation. Modern slavery is a key component of our focus on human rights, and we shall seek to integrate even more our focus on these areas and develop a broader range of procedures and programs in the group.

Compliance with all policies is monitored internally by the management and evaluated independently by Internal Auditing during the programmed commercial audits.

Our Supply Chain:

We seek to associate ourselves with providers whose ethical principles are aligned with ours, and we expect that they will operate in fair and ethical workplaces. Our supply chain is administered by our department of Group Acquisitions, which operates as a unique global function structured in all lines of business and jurisdictions.

Our providers will be asked to complete a self evaluation of providers regarding modern slavery and human trafficking. This includes analyzing the risk of modern slavery and human trafficking in the jurisdictions where they operate, and establishing policies and procedures that they have in order to mitigate this risk.

We have performed modern desk audits on slavery and sessions for the exchange of knowledge with 7 principal contractors and consultants who have been invited frequently to competitive bidding processes or who have received projects adjudicated in 2019. In addition, follow-up emails were sent to the 7 principal contractors and consultants with sample directives and documents about how to improve and increase awareness and compliance regarding modern slavery inside their organizations.

In addition, we will seek to introduce additional controls by including language regarding compliance with laws and policies against slavery and human trafficking in contracts with new providers. We also audits (through sampling, based on risk) certain providers and operations for modern slavery and human trafficking and other risks.

We have a direct confidential line, administered externally, for complaints and irregularities that is available for all DP World workers and third parties that can be used for reporting alleged violations of human rights. All those reporting are protected against reprisal of any kind.

Areas of Risk in Our Business and Supply Chains

Risk of modern slavery and human trafficking varies according to the jurisdiction and the sector. Therefore, we created a working group to address (sic)