Terms and Conditions

Modern Slavery Act

Introduction 

This Statement is Dukes International Co.,Ltd Modern Slavery Statement (the “Statement”) and covers the period of July 1, 2022 to June 30, 2023 (“Reporting Period”). This Statement applies to Dukes International Co.,Ltd and the listed subsidiary entities, including Dukes Manufacturing Co Ltd and their affiliates and related companies (together, “Dukes”, “we”, “us” or “our”). The Statement has been produced in accordance with Australia’s Modern Slavery Act (2018), and the United Kingdom’s Modern Slavery Act (2015). This Statement outlines the steps Dukes has taken to identify and develop a strategy designed to better manage our exposure and ensure continuous improvement of the risks of modern slavery to its supply chain and business operations

About Dukes

Dukes is an Australian owned protective glove manufacturer with state-of-the-art manufacturing facilities in Malaysia and Thailand, servicing the world’s largest international markets such as the USA and the Europe and the Middle East. Dukes production facilities adhere to the highest degree of global manufacturing standards. Our facilities will comply ISO 9001:2015, ISO 13485 2016, EN ISO 13485:2016 management systems and are based on exemplary regulatory compliance. Our capabilities are assessed and certified by  international governing bodies, assuring a fair workplace and a quality finished product. Dukes powder free nitrile gloves will be FDA 510k, CE and TGA certified to match the required EN455, EN420, EN374-1-2-3-4-5, ASTM D6319 / 6978 – 05 standards that allow for legal and safe usage across the selected segment.

Our Business and Dukes Modern Slavery Risks

Dukes recognizes that modern slavery is a significant worldwide problem and commends the efforts of governments and the private sector to eradicate it. Dukes  is committed to acting ethically and with integrity in all our business relationships and maintaining and improving systems and processes to avoid complicity in human rights violations related to our own operations, our supply chain, and our products. Dukes has zero tolerance for any form of modern slavery in our business and we are fully committed to preventing and detecting it. Based on our business model and geographical footprint, Dukes believes that our risk to modern slavery is limited, because Dukes does not have intricate supply chains, multiple contractor or subcontractor levels, or vendor relationships with large manufacturing businesses where modern slavery has been found to be an issue. In addition, the systems and methods that we use to contract with suppliers are managed centrally.

However, Dukes recognizes that all major organizations have a risk of modern slavery -- even if that risk lies in non-strategic sourcing categories or further down the supply chain. Of interest to us are categories such as fruit and vegetables, coffee, cleaning, handy person/multi-trade, grounds maintenance, solar panels, tech hardware, uniforms (including uniforms of contracts and cleaners) and promotional materials.For many of these categories, the risk lies further down the supply chain, so we are committed to working with our suppliers to improve compliance and transparency related to modern slavery. Dukes continually reviews its supply chains and operations to reduce the possibility that any of our business activities contribute to or facilitate modern slavery

Consultation

During the Reporting Period, a Modern Slavery Working Group (the “Working Group”) was established, which included representatives from across Dukes. The members of the Working Group have supported the preparation of this Statement. In addition to the Working Group, Dukes also engaged with external experts to assist our understanding of the obligations under applicable modern slavery legislation and assist in the preparation of this Statement. The following sections summaries our focus during the Reporting Period and the outcomes of this work.

How Dukes Addresses Its Modern Slavery Risks

Our Values As with everything we do, our Dukes values guide us and serve as a gut check that we are being true to who we are as a company. The following core values and beliefs define what’s important to us:

1. Open company 

2. Be the change you seek

3. Play as a team

4. Employ balance and patience in your team

5. Do not mess with your customer

Assessing Modern Slavery Risk

Dukes has established a central procurement function in Australia and the United States. Given the nature of our business, our supply chain mostly consists of the sourcing of raw materials and the hiring of independent consultants and other service providers and the procurement of other raw materials, manufacturing equipment. Suppliers and business partners are subject to various forms of due diligence, including the verification of information provided to Dukes.Selective, risk-based due diligence exercises are also performed on our business partners and supply chain on an as-needed basis. These due diligence processes ensure we contract with reputable suppliers across all procurement categories and minimizes our exposure to modern slavery.

Code of Business Conduct and Ethics

Our Code of Business Conduct and Ethics (the “Code”) sets out certain standards of conduct to aid our directors, officers, employees and contractors in making proper ethical and legal decisions when conducting business for us and performing their day-to-day duties that aligns with our values and policies, including those on human rights. Our Code includes reporting procedures and accountability provisions, and provides for protection against retaliation for those making a report. In the event of violation of our Code, disciplinary actions may include immediate termination of employment or the business relationship. Our Code is available externally on our website so anyone is able to report any concerns or questions regarding any potential violations of the Code or any of our other policies or any applicable law, rules or regulations, including, but not limited to, slavery and human trafficking violations.

Our Code is distributed annually to all directors, officers, employees and contractors who are required to acknowledge they understand and are compliant with the Code. Through the Code, our company values, and the full range of our other policies, we seek to promote honest and ethical conduct, deter wrongdoing and support compliance with applicable laws and regulations in every aspect of our business. In addition, during the fiscal year, we adopted a Supplier Code of Conduct which will apply to each supplier with whom we do business. Amongst other things, our Supplier Code of Conduct prohibits the use of forced labor within our supply chain.

Ongoing Monitoring of Modern Slavery Risk

We continuously monitor the performance of our critical suppliers through our supplier business case review process.
 

If any breaches occur or we have reasonable grounds to believe that slavery and human trafficking are taking place, we would take the following actions:

● Evaluate the severity of the issue and seek expert guidance;
● If severe, determine if Dukes can exit the relationship without placing further harm to the victim(s); or
● If not severe or if the relationship cannot be exited without placing further harm to the victim(s), Dukes will work with the vendor to develop an improvement plan and associated audits at regular intervals in order to improve performance.
 

Reporting Concerns Related to Modern Slavery
Dukes offers multiple reporting channels to our employees, consultants, suppliers, and business partners, including a web portal and telephone hotline that provide individuals with the opportunity to report concerns anonymously. We promote awareness of these reporting channels through internal policies, communications and training. We also prohibit retaliation against anyone who, in good faith, reports any matter relating to modern slavery or who assists in the investigation of a reported concern. Assessing Our Measures and Next Steps

The Working Group is responsible for assessing the effectiveness of actions taken to prevent modern slavery. The actions taken, which are described in this document, all contribute directly and indirectly to Dukes modern slavery prevention program. Dukes recognises that these actions have not fully eliminated modern slavery risk and that the Working Group must continue to develop its program. An Agile mindset is at the core of what it means to be an Dukes, and we have adopted a principle of continuous improvement and ensure that we act swiftly and iterate constantly – rather than wait to develop a perfect program. This Statement represents the baseline of our efforts to reflect on what actions we have taken and bring further focus to how we approach this global issue. We have scrutinized the steps that we have put in place to mitigate the risks of modern slavery to our business, and will continue to monitor and enhance our approach accordingly. We recognize and understand the importance of the laws regarding modern slavery and are committed to reviewing and assessing the risks in our supply chain. Over the course of the coming fiscal year, we will be reviewing our supplier contracts and procurement processes to ensure continued compliance with applicable law.