Slavery and Human Trafficking Statement 2021-2022

We aim to have a positive effect on the communities in which we live and work. From teaching unemployed young people the interview skills they need to get a job, to helping charities expand so they can feed and shelter even more people, we’re using our expertise to make a difference.

How we work

At the same time, how we work is as important as what we do. We recognise that our work carries with it an enormous responsibility, and our guiding principle is to treat everyone fairly and their data with respect.

Our structure and supply chain

Experian plc operates its business through its subsidiaries globally, the majority of which are wholly owned. A list of the regions in which we are operate can be found at https://www.experianplc.com/contact-us/region. We have a well-developed system of internal authorities, controls and policies within the Group. Experian plc and its subsidiaries employ approximately 17,800 people in 45 countries. The Group corporate headquarters are in Dublin, Ireland with operational headquarters in Nottingham, UK; Costa Mesa, CA, USA; and São Carlos, Brazil.

Each year Experian Group companies spend c$1.5bn with external suppliers on goods and services. The majority of this spend is on IT, professional services, data and marketing. Given the nature of Experian’s business we believe the risk of modern slavery in Experian’s supply chain is low compared with businesses operating in other sectors.

Our supply base is heavily weighted towards service based providers rather than the purchase of manufactured goods. Most of the manufactured goods that we do purchase are purchased from large multinational corporations who have their own supply chain principles and ethical standards in addition to agreeing to ours where appropriate.

We believe the risk of modern slavery in our supply chain is low, however, we are not complacent and will continue to focus on improving our procedures and policies to ensure that there is no modern slavery in the Experian supply chain. This year we continued to work with the Slave Free Alliance, a global movement working towards a slave-free supply chain on improving our own processes and creating a better tomorrow for those who may be subjected to modern slavery. 

Our Standards and Policies

Experian does not tolerate any form of modern slavery or human trafficking whether internally or within our supply chain and the leadership team are aware of the risks of modern slavery.

As part of the Experian Group, Experian Limited operates to the same modern slavery standards and with the same controls as the other operating subsidiaries within the Group.

Our employees:

• are provided with a written contract of employment which sets out their rights as employees clearly and which comply with local laws;
• undertake training in relation to our ethical standards;
• are required to comply with our Global Code of Conduct which is published at https://www.experianplc.com/responsibility/our-policies/ and rolled out to staff to complete an individual training module;
• are provided with a global confidential helpline where any concerns can be reported anonymously 24 hours per day;
• are provided with an all employee communication highlighting the risks of modern slavery and how they can report any suspected instances; and
• in the procurement team are provided training on modern slavery on an annual basis.

Our suppliers:

• are obligated under our contractual terms and conditions to maintain acceptable controls and standards in respect of their employees and their rights and freedoms, and replicate this in any contract with subcontractors that they may use to deliver services to us; 
• are assessed as part of our Procurement process - we undertake appropriate due diligence checks as part of this process and include a section of modern slavery at the beginning of any new transaction;
• must comply with our Supply Chain Principles as a minimum, which can be found at https://www.experianplc.com/responsibility/our-policies/ and specifically covers human trafficking, modern slavery and forced/child labour; and
• may be randomly selected and reviewed to assess their compliance with our requirements on modern slavery, and their adherence to the Act as part of our risk based assessment of our existing supply chain. This may be in the form of a questionnaire, telephone interview or face to face meeting and an onsite review of the premises from which they provide services to us.

Due Diligence

When starting a new relationship with a supplier, we:

• ask questions at the outset of any competitive process around a supplier’s modern slavery compliance;
• may conduct onsite assessments of supplier premises where services are to be delivered and request to see policies and statements around modern slavery; and
• obligate suppliers to comply with our supply chain principles or have their own equivalent.

Risk Assessment

We continue to assess our existing supply chain by carrying out targeted desktop reviews of our key suppliers, selecting those we believe are more exposed to potential modern slavery risks.

This assessment questionnaire includes a series of questions to ascertain the supplier’s knowledge, approach and policies relating to modern slavery risks in their business. This includes reviewing their modern slavery statements and supporting policies where available. If we have concerns with supplier responses, we follow up with either a face to face interview (current COVID-19 pandemic restrictions permitting) or telephone conference to discuss these further, and ask for a plan to alleviate and address our concerns.

Training

Information on the risks of modern slavery and how employees should report any suspicions and findings is included in the annual employee code of conduct training.

All members of the procurement team have attended more detailed training on modern slavery. This explains the purpose of the Act, Experian Limited’s approach and what members of the procurement team should do if they suspect or uncover any form of modern slavery in our supply chain.

Summary of Activities for the Year ended 31 March 2021

We undertook 10 desktop reviews of our key suppliers. All had a published modern slavery statement and there were no significant issues raised that required immediate attention.

During the year, the Global Head of Internal Audit has confirmed that no calls were received concerning modern slavery in our supply chain to our global confidential helpline.

Slave-Free Alliance continue to work with us and we have presented our progress to them for the year ended 31 March 2021 against our three year plan. We have created a quarterly Modern Slavery steering group and Slave Free Alliance attend to provide us with an external perspective.

We have put in place plans for our Supplier Modern Slavery awareness event and will deliver this during the financial year ended March 2022.

Funding from Experian has helped Hope for Justice to scope out a preferred supplier for a Case Management System allowing them to store and track live and closed cases in a single, secure database. This will improve operational effectiveness and allow more resources to be diverted into victim recovery and support.

We have established a process, in partnership with Hope for Justice, working with our Fraud & Authentication and Compliance teams to streamline three key processes:

• adapting the identity verification process which, in most circumstances, would be unsuitable for victims of slavery (little or no identification documents).
• with the consent of victims sending encrypted statutory reports directly to Hope for Justice, reducing costs/waiting times.
• supporting victims of financial abuse through our dispute process (where financial accounts have been fraudulently opened by impersonation or coercion).

Proposed actions for the next financial year

1. Continue our partnership with Hope for Justice to drive awareness and support them financially to provide advocacy support for modern slavery victims;
2. Undertake refresher training on modern slavery via a face to face session with the procurement team, and deliver appropriate targeted training to internal staff in high risk areas (outside of the procurement team);
3. Formalise Modern Slavery KPIs and performance measurement mechanisms;
4. Maintain an on-going programme of supplier reviews which include a deeper focus on modern slavery risks, including onsite assessments (COVID-19 pandemic conditions permitting);
5. Repeat the all-employee electronic communication which highlights what modern slavery is, how employees can report any concerns or suspicions and where they can find more information;
6. Continue to use the quarterly Modern Slavery steering group to drive our agenda; and
7. Working with our internal compliance colleagues, review processes and policies on Modern Slavery for Mergers and Acquisitions targets as part of our overall due diligence. 

This statement is approved by the Experian Limited Board and signed on its behalf by:

Jose Luiz Rossi

Director

Experian Limited

Date: 24 May 2021