Modern Slavery and Human Trafficking Statement (Financial Year ending 31st December 2023)

Introduction

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that the Dennison Group has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. The Dennison Group has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our Business

The Dennison group of companies is focused on serving the transport industry in Northern Ireland. The Dennison Group comprises:

• Dennison Commercials Limited
• Dennison Rentals
• Dennison Bodyshop
• Dennison Industrial Estates
• Dennison JCB

We are Northern Ireland's Volvo Truck & Bus dealer, with dealerpoints located across the province providing unrivalled Nationwide back-up. We have an extended range of complementary products and services, including commercial vehicle rentals, a specialist bodyshop, a bus PDI centre and commercial units for hire from Dennison Industrial Estates. We also supply a wide range of all makes truck and trailer components. We are also the JCB dealer for construction, industrial and access equipment and generators in Northern Ireland and County Donegal, with a complete offering of sales, service and parts.

Our Supply Chain

The Dennison Group procures a wide range of parts and materials from both the UK and overseas. Volvo Trucks and genuine Volvo parts are procured directly from the Volvo market company in Warwick, England, with non-genuine parts being procured from the UK and overseas countries. Our JCB machinery and parts are procured from the JCB market Company in Rocester, England.

Our Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
2. Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
3. Business Conduct, Ethics & Anti-Bribery policy. This policy sets out our business conduct principles and the ethical standards we display in all our business activities.
4. Employee Code of Conduct. This code explains the manner in which we behave as an organisation and how we expect our employees to act.
5. Corporate Social Responsibility policy. This policy represents our commitment as a business to behave in a socially responsible manner in all our activities and our aim to improve the quality of life of our employees.

Our Suppliers

The Dennison Group will hold our suppliers to account over modern slavery. The Company is in the process of preparing to conduct a due diligence exercise in relation to our key suppliers focussing on identifying the steps they have taken to eradicate modern slavery both within their business and their wider supply chain.

In relation to actions taken during the financial year ending 31^st December 2023, visits were made by senior management to potential overseas suppliers premises in geographical areas which were assessed as having a higher risk of modern slavery or human trafficking. These visits included assessment of the working conditions and practices of these businesses prior to approving them as suppliers to Dennison Commercials.

Training

The Dennison Group is committed to updating and educating relevant staff in relation to the signs of modern slavery and of what to do should they suspect modern slavery or human trafficking is occurring within our supply chain.

Review & Approval

This statement will be reviewed and updated on an annual basis and is approved by the Board of Directors.

John Jenkins

Managing Director

1st February 2024