Development Dynamics Limited (DD) recognises that our business activities have the potential to affect the human rights of our employees, suppliers, subcontractors, clients, and the communities in which we operate. We are unreservedly committed to respecting internationally recognised human rights in accordance with the following frameworks:

• The United Nations Guiding Principles on Business and Human Rights (UNGPs), including the State Duty to Protect, the Corporate Responsibility to Respect, and Access to Remedy.
• The International Bill of Human Rights, comprising the Universal Declaration of Human Rights (UDHR), the International Covenant on Civil and Political Rights (ICCPR), and the International Covenant on Economic, Social and Cultural Rights (ICESCR).
• The International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work (1998) and its Follow-up, specifically the eight fundamental conventions covering: 

(i) freedom of association and the effective recognition of the right to collective bargaining; 

(ii) the elimination of all forms of forced or compulsory labour; 

(iii) the effective abolition of child labour; and 

(iv) the elimination of discrimination in respect of employment and occupation; together with the ILO conventions on occupational safety and health (C155) and decent working hours (C1, C14, C30, C47, C106).

• The ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy (MNE Declaration).
• The UN Sustainable Development Goals (SDGs), particularly SDG 8 (Decent Work and Economic Growth), SDG 10 (Reduced Inequalities), and SDG 16 (Peace, Justice and Strong Institutions).

This Policy applies to all DD operations, projects, procurement activities, and business relationships worldwide. It is publicly available on our website and communicated to all associates, suppliers, clients, and relevant stakeholders.

2. SCOPE

• All DD employees/consultants, directors, officers, and board members, regardless of location or contract type (permanent, temporary, or intern).
• All independent contractors, consultants, and short-term engagements working on behalf of DD.
• All suppliers, subcontractors, and business partners providing goods or services to DD.
• All client projects and engagements where DD’s work may directly or indirectly affect workers, communities, or end-users.
• All joint ventures, consortium partnerships, and affiliate network members.

3. GOVERNANCE AND ACCOUNTABILITY

This Policy has been formally reviewed and approved by the CEO of Development Dynamics. The CEO retains ultimate oversight responsibility for human rights performance and receives quarterly updates on grievances, risk assessments, and remediation activities.

• CEO (Dr MaqC Eric Gitau): Ultimate accountability for human rights strategy; approves major policy changes; reviews annual Human Rights Performance Report.
• Ensures resources are allocated for human rights implementation; receives immediate notification of Category 3 (Critical) grievances and red-flag assessments.
• Human Rights Lead (Victor Kimanthi): Operational ownership of this Policy; conducts due diligence; maintains the Grievance Register; leads investigations; reports to Board quarterly.
• All Staff: Responsible for upholding this Policy in daily activities; must report suspected human rights impacts through established channels.

 4. DD’S HUMAN RIGHTS RESPONSIBILITIES

In line with the UNGPs ‘Protect, Respect and Remedy’ framework, DD commits to:

5. SALIENT HUMAN RIGHTS RISKS

Risk Identification and Prioritisation Methodology:

DD identifies and prioritises salient human rights risks based on the severity and likelihood of potential or actual impacts, the number and vulnerability of people potentially affected, DD’s connection to the impact, the geographic and operating context, and DD’s ability to prevent, mitigate or influence the impact. The assessment considers DD’s own operations, suppliers, clients, projects and other relevant business relationships and is reviewed at least annually or when significant changes occur.  DD has identified the following salient human rights risks across our operations and value chain—those at risk of the most severe negative impact through our business activities

INTEGRATION INTO BUSINESS PROCESSES

This Policy is operationalised through the following integrated procedures and documents:

7. TRAINING AND COMMUNICATION

All DD associates receive training on this Policy during onboarding and annually thereafter. Project-specific human rights briefings are conducted at kick-off for all Medium and High-risk projects. Suppliers receive the Supplier Code of Conduct and are required to acknowledge understanding before contract commencement.

8. MONITORING, REPORTING, AND REVIEW

DD will evaluate the effectiveness of its human rights strategy and controls at least annually and through quarterly monitoring of relevant indicators. Evaluation will consider progress against human rights objectives, risk assessment findings, grievance trends, remediation outcomes, supplier performance, stakeholder feedback, training completion and recurrence of identified impacts.

The Human Rights Lead will document lessons learned and recommend changes where controls or responses are not effective. Material findings and recommended improvements will be presented to the CEO and Board for review and action. Changes arising from the evaluation will be assigned an owner, implementation deadline and monitoring indicator. DD will communicate material progress, lessons learned and improvements through its annual Human Rights Performance Report.

9. NON-COMPLIANCE AND REMEDIES

Failure to comply with this Policy by any DD staff member may result in disciplinary action, up to and including termination. Suppliers who fail to meet the standards set out in the Supplier Code of Conduct will be subject to corrective action plans, contract suspension, or termination, depending on severity and responsiveness.