Responsible Purchasing & Modern Slavery Risk Assessment Policy

Document owner: Senior Management Team

Effective date: 22 September 2026

Applies to: Day-Impex operations and supply chain

Review date 22 September 2027

QMS status: Controlled policy / procurement control

Version: 1.0

Prepared for: PPON / public procurement evidence

Approval status: Signed and approved

1. Purpose

This policy sets out how Day-Impex identifies and controls the risk that its own purchasing practices could place
unreasonable pressure on suppliers and contribute to forced labour, debt bondage, excessive overtime or other forms of labour exploitation. It supports Day-Impex’s Modern Slavery and Human Trafficking Policy & Statement and forms part of the organisation’s risk-based supplier due diligence and ISO 9001 supplier management approach.

2. Scope

This policy applies to employees involved in purchasing, supplier selection, order placement, contract management, finance, operations and supplier review. It applies to goods and services purchased for Day-Impex operations and to goods purchased for resale or distribution under customer and public-sector contracts.

3. Responsible Purchasing Principles

  • Day-Impex will not knowingly use purchasing practices that create unreasonable pressure on suppliers to reduce labour standards or compromise worker welfare.
  • Commercial negotiations will be conducted fairly and with regard to supplier capacity, agreed lead times, payment terms and legal obligations.
  • Purchasing decisions will consider modern slavery risk alongside quality, service, price, continuity of supply and compliance.
  • Where an urgent or exceptional requirement is necessary, the responsible manager must consider whether the request could create excessive overtime, unsafe working practices or inappropriate subcontracting.
  • Higher-risk suppliers may be subject to enhanced due diligence, contractual conditions, evidence requests, corrective action plans or further review.
  • Concerns relating to forced labour, recruitment fees, debt bondage, worker intimidation or other modern slavery indicators must be escalated in accordance with Day-Impex reporting procedures.

4. Purchasing Practice Risk Assessment

Day-Impex will assess the following purchasing practices at least annually and when a material change in supply arrangements occurs:

  • Lead times and urgent orders – whether deadlines could create pressure for excessive overtime, unsafe working or unapproved labour sourcing.
  • Pricing and commercial pressure – whether negotiations or cost reductions could make lawful and ethical labour practices commercially unrealistic.
  • Payment terms and payment performance – whether late or unreasonable payment terms could create cash-flow pressure affecting workers or labour providers.
  • Order changes, cancellations and volume fluctuations – whether short-notice changes could lead to excessive overtime, precarious labour or inappropriate subcontracting.
  • Forecasting and supplier capacity – whether expected volumes are communicated sufficiently for suppliers to plan labour and production responsibly.
  • Use of subcontractors, labour agencies and temporary workers – whether additional labour-chain risks require enhanced checks.
  • Geographic, sector and product risk – whether the source country, manufacturing sector or nature of the goods indicates a higher modern slavery risk.

5. Procurement and Supplier Management Controls

Stage Modern Slavery Consideration Day-Impex Control
Need / requirement definition Could the requirement create unrealistic delivery, cost or labour pressure? Set realistic specification, quantity and timing; identify higher-risk sourcing.
Supplier selection/evaluation Supplier labour, geography, sector, subcontracting, and compliance risk. Risk-based due diligence, certification checks and supplier assessment.
Contract/purchase commitment Are ethical labour expectations clear? Include appropriate requirements, especially for higher risk suppliers.
Order placement Could timing, volume, or price create pressure? Confirm capacity where necessary; avoid unreasonable last-minute demands.
In-life management Has risk changed or has any concern been raised? Annual supplier review, ongoing monitoring, and corrective action where required.
Renewal/end review Were any labour or modern slavery issues identified? Consider performance, due diligence evidence, and unresolved actions before renewal or exit.


6. 2026 Purchasing Practices Modern Slavery Risk Assessment

Day-Impex has reviewed its purchasing practices against the risk areas below. No current purchasing practice has been identified as creating a high modern slavery risk. The assessment recognises potential pressure points and records the controls that should be maintained.

Risk area Potential modern slavery pressure Current control Assessment Action/evidence
Lead times/urgent orders Excessive overtime, rushed labour sourcing, or unsafe production. Reasonable lead times wherever practicable; capacity considered for urgent requirements. Low/controlled Review exceptions and retain supplier communication where material.
Pricing / cost pressure Supplier may cut labour standards or use vulnerable labour to protect margin. Commercial negotiation balanced against quality, compliance and continuity. Low / controlled Escalate where a price appears incompatible with compliant supply.
Payment terms Cash-flow pressure may affect wages or labour providers. Agreed terms are communicated and managed through normal finance controls. Low / controlled Monitor material late payment issues and supplier concerns.
Order changes / volume spikes Short-notice increases may create overtime or agency labour pressure. Material changes communicated as early as practicable; supplier capacity considered. Low / controlled Record significant changes and supplier capacity confirmation.
Subcontracting / agency labour Reduced visibility of recruitment practices, fees or worker conditions. Use of subcontractors or agency workers is a supplier risk factor in due diligence. Moderate inherent / controlled Enhanced checks for suppliers where reliance is material.
Geographic / sector risk Higher-risk manufacturing or labour markets may increase exposure. Risk assessment considers geography, industry sector and nature of goods/services. Risk-based Apply enhanced due diligence where risk profile increases.
Supplier non-compliance Unresolved labour concerns could persist. Investigation, escalation, corrective action and potential termination depending on circumstances. Controlled Track corrective actions to closure and review continued approval.


7. Supplier Due Diligence and Annual Review

Supplier risk is reviewed through Day-Impex’s supplier management process. The review may include supplier
questionnaires, certification and compliance checks, contractual requirements, audit evidence and other information proportionate to the supplier’s risk profile. Higher-risk suppliers may be required to provide additional evidence relating to recruitment, labour providers, subcontracting, worker grievance arrangements and corrective actions.

8. Response to Concerns and Corrective Action

  • A concern must be escalated to senior management and investigated promptly and proportionately.
  • Where appropriate, the supplier will be required to explain the issue, identify root cause and provide a time-bound corrective action plan.
  • Day-Impex will consider worker protection and remediation, supplier cooperation, severity, recurrence and complicity before deciding whether trade should continue, be suspended or be terminated.
  • Suppliers will not be automatically de-listed where they are not complicit and effective remediation is possible.

9. Training, Responsibilities and Records

Relevant purchasing, procurement, operations and management staff will receive appropriate modern slavery awareness so they can recognise risks in purchasing decisions and supplier behaviour. Supplier reviews, risk assessments, material due diligence evidence, reported concerns and corrective actions will be retained within Day-Impex’s controlled management records.

10. Monitoring and KPIs

  • Percentage of active Tier 1 suppliers reviewed within the annual review cycle.
  • Percentage of identified higher-risk suppliers receiving enhanced due diligence.
  • Number of purchasing-practice exceptions or concerns reviewed by senior management.
  • Number and closure status of supplier corrective actions relating to labour or modern slavery risk.
  • Completion of relevant staff awareness / training.

11. Review and Approval

This policy and the purchasing-practice risk assessment will be reviewed at least annually, and earlier where there is a significant change in suppliers, sourcing geography, product category, contract requirements or identified modern slavery risk. Material findings and required actions will be reviewed by Senior Management and, where appropriate, the Board.

Accompanying Documentation:

Approved by: David Jones - Managing Director
Signature: SIGNED
Date: 22 September 2026
Document status: This policy becomes approved evidence once authorised in accordance with Day-Impex governance and retained as a controlled QMS record.