Working responsibly

The Board’s primary focus is to ensure the protection and enhancement of long term shareholder value taking into account the interests of other stakeholders for the performance of the company. The board is accountable to shareholders for the performance of the company, it directs and monitors the business and affairs of the company on behalf of shareholders and is responsible for the company’s overall corporate governance. Operational performance is closely monitored in a way that is compliant to all historic and recent legislation, across all our companies and business units.

Modern Slavery and Human Trafficking Statement

Introduction

The Delivery Group is committed to acting ethically and with integrity, and ensuring that modern slavery and human trafficking are not taking place in our business or supply chains. This Modern Slavery and Human Trafficking Statement is published in accordance with the Modern Slavery Act 2015 and sets out the steps we have put in place and continue to develop, to tackle the risk of modern slavery and human trafficking within our Group and supply chains.

Company Structure

At The Delivery Group we specialise in international and domestic eCommerce and mail distribution services, delivering over a billion items a year. We operate from five major locations in the UK and employ over 500 staff.

This statement applies to all members of The Delivery Group, and for the purpose of this statement we will use the terms ‘we’, ‘our’ and ‘Group’ to include the following companies:

Secured Express Limited t/a The Delivery Group
CMS Network (London) Limited t/a The Delivery Group
Postal Choices Limited t/a OnePost
ETrak Logistics Limited

Policies in relation to Slavery and Human Trafficking

We all have a duty to be alert to risks, however small. As such, our policies set out our expectations and commitments to our people, suppliers and clients. Our policies are readily available to our employees, and those not published on our website are available to customers and suppliers on request. Relevant policies for modern slavery and human trafficking include:

• Corporate Social Responsibility (CSR) Policy – Our CSR policy summarises how we manage our environmental impacts and how we work responsibly with suppliers and local communities

• Whistleblowing policy – We encourage all our staff, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Group. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers, or others who have concerns can complete our confidential disclosure form

• Employee code of conduct – Our Employee code of conduct, contained in employee handbooks, makes clear to employees the actions and behaviour expected of them when representing the Group. We strive to maintain the highest standards of employee conduct and ethical behaviour when managing our supply chain

• Supplier/Procurement code of conduct – We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions where they do not meet the standard. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship

• Recruitment policy – We use only specified, reputable employment agencies to source labour and always verify the practices of any new agency we use before accepting workers from that agency. We regularly audit employment agencies we use to ensure that all the right to work and identity checks are being carried out

• Anti-Bribery and Corruption policy – We are committed to the practice of responsible corporate behaviour and as such our policy sets out the standards of behaviour we expect to ensure the integrity of the supply chain.

Due Diligence

As part of the supply chain, we undertake due diligence to ensure we are not entering into a contract or service that could be misconstrued, and demand of our suppliers the highest credentials. This also includes any agencies that supply our companies with temporary labour.

The following activities are considered to be at high risk of modern slavery or human trafficking:

• Employment of foreign nationals who are not permitted to work in the UK and vehicles or those of our suppliers crossing UK borders

To mitigate these risks, we undertake thorough company checks and satisfy ourselves of the viability of any companies we do business with. We would also take account of any Foreign Office advice relating to countries we provide services to.

Education is key to the understanding and the upholding of our policies and as part of our management toolkits, we actively ask all management and our employees to raise concerns if they believe any aspect of our supply chain is compromised by human trafficking or slavery.

The Delivery Group undertakes rigorous internal verification of employees, with interviews, work histories, CRB checks, right to work checking and professional screening to reduce the risk of employing a person that is not registered or allowed to work in the constituent supply chain. These policies must also be able to be audited with all our temporary labour suppliers (Agencies), ensuring against legislative compliance breaches.

Directors of the Group are committed to ensuring that there isn’t any modern slavery or human trafficking in our supply chains, by auditing and choosing world brand leaders in delivery. Our Modern Slavery policy reflects our commitment to act ethically and with the utmost integrity in all our business relationships. We work to ensure our suppliers adhere to our policies and when correct to do so back-to-back our employment criteria to ensure bestin-class systems and controls are used. With the issuance of strict, moral codes and practices to our partners, we regularly carry out audits through our internal and HR departments, assisting to drive out all aspects of human trafficking and slavery from our supply chains.

Responsibility for our anti-slavery initiatives are as follows:

• Policies Human Resources in each business unit are responsible for creating and reviewing policies. The process by which policies are developed is to review best practice and legislation and adapt policy to the needs of the organisation.

• Risk assessments The Compliance Manager and Health & Safety and Process Manager is responsible for risk assessments in respect of human rights and modern slavery by a process of planned review, audit and control activities.

• Due diligence Human Resources and Finance departments, along with the Compliance Manager and Health & Safety and Process Manager are responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.

Training

Our staff are required to undertake various online training programmes both at induction and then refresher training annually. This training is used in conjunction with our company policies to ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains. All staff have easy access to, and are required to read, sign and adhere to, the company policies that are in place across the Group.

Performance indicators

The Group uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains: The use of labour monitoring and payroll systems; Outcomes of employment agency auditing process; Annual risk assessment data; Number of complaints raised.

The Board of Directors absolutely believe that with driving the correct internal and supplier behaviours, slavery in any form will be removed from day-to-day life. It is a basic prerequisite that we remove any instance across our supply chain, and therefore we will continue to strive to ensure that all companies across the Group keep modern slavery risks at the forefront of their processes. Accordingly, this statement is approved by the Board of Directors at this time and will be reviewed annually or indeed when a change of legislation
means it is relevant and proper to do so.

Name of Director: Michael Owen, Group CEO
Date: 1st May 2023

We care about the environment and strive to limit the impact of our activities in the following ways:

• We are committed by achieving and in certain cases exceeding current legislation and regulations, working to relevant codes and accreditation such as BSI 39001 for Transport, ISO14001, FORS and CLOCs to reduce our impact on the world around us. These elements drive better recycling and driver behaviours with the aim of reducing our carbon footprint and making our workplace a safe one.
• We look to reduce our energy consumption by purchasing the most fuel effective transportation, investing in LED lighting, body heaters rather than air heating and we aspire to keep reducing our emission of greenhouse gases from our warehouses and supply chain.
• We invest heavily in technology to route plan effectively, coupled with optimal vehicles and aerodynamics, we have made large gains in fuel economy. Couple this with web based meeting rooms and video conferencing we are striving to reduce the mileage consumed for meeting, and client visits.
• Our polices are to reuse equipment in different ways to reduce landfill, we have within the group, total recycling solutions for cardboard, plastics and metals (ferrous and non-ferrous), ensuring we do not add our waste to the millions of tonnes processed each day in the UK.
• When re-cycling isn’t an option we have balers and compactors to ensure we are not using waste disposal businesses regularly and consuming fuel to remove half capacity bins and recycling units.
• We promote all our actions across the group encouraging all employees in all of our companies to reduce waste, reuse supplies and recycle in the most ecological way, we consider the best way of reusing MHE, with pallets recycled up to 20 journeys when it is safe to do so.
• We ensure our suppliers are ethical and we carry our regular audits both internally and with external suppliers, to ensure we are as carbon neutral in our undertakings as possible.
• We aim at all times to be good neighbours and to be active in our local communities.

Employee Benefits and Rewards

• We aim to provide a level of pay that is above the minimum wage and more aligned to the living wage, this will always represent a competitive level of pay to the work undertaken and the local area pressures. We offer benefits relative to the job and skill level, with additional allowances such as mobile worker allowance, and enhanced schemes such as Perkbox, offering cycle to work schemes, gym membership and retail discounts
• Diversity within the working day is important and we absolutely value our full time and part time staff, and if possible we happily agree to home working and flexible working practices, that offer that all important work, life and family balance. Our roots come from family businesses and this is a fact we never lose sight of
• We recognise loyalty and integrity, both through monthly and annual campaigns, recruitment rewards, and long service cards, presentations and voucher schemes.
• We are fully committed to equal rights and opportunity in employment
• We actively encourage technology to break down the barriers of travel, with sharing of workspaces, video conferencing, Webex and online demonstration tools
• When travelling we promote the use of car sharing, and promote the use of low emission cars, with electric hybrid vehicles available to staff as a company car option. Our vehicle policies are changing to ensure we are prepared for London’s Ultra Low Emission zone in 2020
• We aim to support employees charitable initiatives and offer schemes such as match funding of charitable donations..

• We strive to provide a safe working environment, with high levels of general housekeeping and a clutter free environment across our operations. We have IOSH and NEBOSH trained individuals on hand to review and produce safe ways of working, risk assessments and governance. We have highly trained ISO9001 audit specialists to ensure we are keeping standards and guide us on the correct path
• We ensure that clean canteen facilities, hygiene stations and rest rooms are to the highest standard for all employees, these canteen facilities enable a relaxed atmosphere at break and rest periods
• We measure our internal employee turnover and use this as an indicator of pay, conditions and benchmarking across our sectors
• We have a no smoking policy in all our buildings and company vehicles and provide designated areas across all our sites for smokers.

• We are always looking to improve our internal communications to ensure that the Group and its companies reach all staff, wherever they are based. This includes a range of approaches from traditional notice boards to email and employee forums. We hold shift briefings and health and safety briefings every day to ensure continual learning and when accidents happen, we review our processes to ensure we can, if possible, mitigate the risk in the future. A regular newsletter is published, this gives our employees an overview of our challenges, successes, initiatives and opportunities. Employees are encouraged to provide feedback and we encourage an open dialogue at all levels
• Our Employee Forum representatives, come for all levels within the business, this we believe is vital to give a rounded view of our operations and drives engagement into items such as corporate image, uniforms and facilities
• Annual conferences for our senior management team ensure we deliver the overarching business plan, fostering a “stronger together” attitude and a collaborative approach to servicing our customer’s needs.

• We encourage employee training from within, with NVQ courses, specialised skilled course such as NEBOSH, ISO9001 chief auditor, CPC international, RoSPA assessor courses
• Our Management Development Programme aims to identify talent then provide tailor-made training through which we encourage and develop tomorrow’s leaders
• We enable our finance function to flourish with funding and study lease for ACCA and CIMA chartered qualifications.

The Delivery Group prides itself in its innovative customer interfaces.

Our Group operate bespoke IT systems delivering outstanding services to our clients. These have to be robust, agile and open in order to interact with WMS, and other order processes.

We use many solutions on a daily basis to help protect our systems and our customers from ransomware attacks during IT downtime. Good practice and protocols are key to the success of our business and the way we operate.

Our infrastructure is high availability with multiple cross site replication, we have multiple firewalls and have deployed server and local copies of antivirus software to ensure that remote and office workers have the same level of protection. Our businesses take IT and physical security very seriously. We are ISO27001 accredited and hold Cyber Essentials Plus within The Delivery Group. We utilise private cloud technologies and physical on site server cluster’s protected with the latest definitions of antivirus and firewalls.

Communication is key to prevent attacks, as we must educate all our staff to identify a hoax or a malicious email or website, this is done by simply reminding them on a monthly basis of the latest threats, the techniques employed and if they deem anything suspicious to raise this with their line managers or IT department. Whilst we cannot prevent all attacks, education minimises risks to our servers and data.

Simple straight forwards steps to prevent attacks include looking at the structure of the email, the formatting and its features, beware if an email exhibits any of the following-

• It’s from a company or individual that you’ve never had contact with previously.
• It asks you to click a link. (These include PDF links, links to a website, if you are seeing a link to click here for say a PayPal payment, remittance or Apple upgrade or Microsoft upgrade, you can hover over the link and easily tell if this is legitimate, if in doubt please contact your internal IT department.)
• It asks you open an attachment, or asks you to enable a macro to access the file
• It has been sent via a public email service and not a business email address.
  e.g. @hotmail.com, @yahoo.com, @gmail.com @ukcmsnetwork.com, @securedmail.co.uk
• It asks you to verify any personal details or account details.
• It does not refer to you by your name.
• It uses poor grammar or spelling.
• It is poorly formatted or uses low quality images.
• It appears to be from an existing contact but the style of language or formatting of the email differs from previous emails.

We pride ourselves in our integrity and security of our systems giving you our customers the confidence that your transactions and supplier is secure and safe.

Our Commitment to Sustainability

The Delivery Group recognises that it is vital to drive improvements in the business’s environmental performance and has
developed this policy to demonstrate the commitment to the environment in which we operate.

We are committed to sustainable development (meeting the needs of the present without compromising the ability of future
generations to meet their own needs) as a guiding principle within our business. Concern and care for the environment is an
integral and fundamental part of this commitment.

We aim to reduce the impact on the environment from our operational activities.

The Company aims to meet its commitment to sustainability through the way in which it provides services to its clients.
Directors, Managers and Staff will collectively take responsibility for this policy and all parties are committed to its success.
A list of key targets is shown in Appendix 1 (this is subject to future technological developments and availability of equipment
supply).

Our Environmental/Sustainability action plan

In our role as a provider of both national and International mail and parcel services, we aim to promote good governance with
both clients and suppliers.

We will endeavour to:

• Encourage employees and contractors to incorporate informed sustainability perspectives within their work.
• Operate in ways that balance social and economic impact and minimise adverse effects on the local community.
• Develop sustainable procurement procedures within all elements of the supply chain.
• Encourage repair, reuse and recycling ahead of the responsible disposal of surplus materials and minimise waste
generation.
• Maximise the efficient use of energy and materials.
• Increase the use of renewable energy sources.
• Take positive actions promoting continual improvement in sustainability performance.
• Develop the capacity of staff to promote the principles and practice of sustainability.
• Encourage other partners to adopt sustainable best practices.

Our current initiatives include:

• Accredited to ISO14001, which promotes best practice for environmental processes.
• Ability to provide estimated carbon reporting on individual jobs for clients.
• Provide a returns management process to help cleanse client databases and reduce waste.
• 100% of secured waste is recycled, and 95% of non-secure waste is recycled.
• LED lighting installed across all sites with communal lighting using motion-sensors to reduce energy use.
• Electric Vehicles in London for collections and deliveries.
• Increased awareness of our suppliers and how we can work to achieve recyclable and recycled products.
• Reduced heating requirements for our warehouses compared to others in the sector.
• Investment in two new energy-efficient hubs.
• Solar panel installation at our head office building which helps to reduce our carbon footprint.
• Double-decker trailers to increase capacity and reduce the number of routes and reduce our carbon footprint.
• Improved consumable management process deployed to reduce dedicated consumable deliveries.
• Hybrid working scheme deployed to reduce travel to work, reducing emissions by over 15000 kg of CO2.
• Free-to-use charging points installed at key sites.

Our future plans include:

• Working with Royal Mail to help reduce the carbon footprint of mailings by improved containerisation and changes to the
existing services.
• Replacing our HGV fleet with electric vehicles once technology is fully established with a proven record of reliability and
appropriate operational mileage range (likely to be second-generation electric HGV vehicles) by 2040.
• Exploring the use of LNG HGV vehicles as an interim step in reducing our emissions in the short term.
• To install additional electric chargers at all sites to fully meet the demands of private car users and visiting clients/
suppliers by 2030.
• Procure all electricity from carbon-neutral sources by 2032.
• Encourage private vehicles to be used by employees for business miles are fully electric or hybrid petrol by 2028
(incentivise staff via increased mileage rates).
• To achieve Carbon Net Zero including our supply chain by 2045.
• Investigate producing solar-powered electricity at other key sites via the use of roof-installed solar panels.

Climate change and its relationship to man-made carbon emissions are significant global issues. TDG recognises the
importance of understanding and improving the environmental impact of mail and parcels and is committed to making
the above changes. However, TDG also acknowledges that some of these changes require additional time or technological
advances not within the control of TDG, and therefore, as an interim measure, TDG will contribute to its Carbon Net Zero aims
by offsetting its Scope 1 and Scope 2 carbon emissions each year through the accredited Carbon Neutral Britain (certified to
the highest standards through the UK and EU Emissions Trading Standard (EU + UK ETS), Gold Standard Voluntary Emission
Reductions (VERs) and the United Nations Certified Emission Reductions (CERs) programmes).