Slavery and Human Trafficking Statement 2017-18
This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 (the “Act”) and constitutes Experian Limited’s slavery and human trafficking statement for the financial year ended 31 March 2017.
Experian plc and its subsidiary companies are committed to protecting our organisation and those people at risk from exposure to slavery or people trafficking in our supply chain, both via directly employed staff and staff working on our behalf via third party vendors.
Organisational Structure and Background
We are the leading global information services company, providing data and analytical tools to our clients around the world. We help businesses to manage credit risk, prevent fraud, target marketing offers and automate decision making.
We also help people to check their credit report and credit score, and protect against identity theft.
Experian plc operates its business through its subsidiaries, the majority of which are wholly owned. It has a well-developed system of internal authorities, controls and policies within the Group. Experian plc and its subsidiaries employ approximately [17,000] people in  countries. The Group’s corporate headquarters are in Dublin, Ireland with operational headquarters in Nottingham, UK; California, US; and São Paulo, Brazil.
Our employees are all provided with a written contract of employment and undertake training in relation to our ethical code and standards. Experian has a Global Code of Conduct and takes its responsibility for implementing this Code very seriously. We appreciate the key role that Experian employees play in maintaining high standards and the Code gives a clear understanding of Experian’s approach to professional and ethical standards and ensures that employees know exactly what is expected so that they can play their part in helping Experian meet those standards. Each employee has a personal responsibility to read the Code, as well as to ensure that they fully understand their obligations and the consequences associated with any breach of those obligations.
We provide a global confidential helpline where our employees can report concerns anonymously 24 hours per day. These reports are reviewed by the Head of Global Internal Audit.
Our Third Party Supply Chain
Each year Experian Group companies spend c$1.5bn with external vendors on goods and services. The majority of this spend is on IT, data and marketing. Spend commitments are made using written contracts. We do not use cash payments for services.
Given the nature of Experian’s business we believe the risk of modern slavery in Experian’s supply chain is low. Below is a chart which gives an overview of the spend in our Global supply base by type:
It shows that our supply base is heavily weighted towards service based providers rather than manufactured goods.
Most of our manufactured goods (typically IT equipment) are purchased from large multinational corporations who have their own supply chain principles and ethical standards in addition to agreeing to ours where appropriate.
The use of service provider contractors in our organisation is largely within our facilities support and IT categories. We do not generally enter into individual arrangements for any of these roles and contract via reputable large facilities management and specialist IT resourcing companies respectively.
On the basis set out above, 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.
Update on activities since our last statement
The Group set itself three key actions for the last financial year. These were:
- Risk assessment of the risk of modern slavery in our supply chain.
- Adoption of ethical language and SA8000 principles in our new standard procurement contracts globally.
- Communication of our ethical standards to all our employees and provision of training.
Risk Assessment of Supply Chain
We have carried out a desktop assessment of our current suppliers in the UK, and selected those we believe are more exposed to potential Modern Slavery risks. This included reviewing their Modern Slavery Statements and supporting policies where available.
Following this assessment process, we have sent out questionnaires to selected suppliers. Dependent upon their responses, suppliers may be selected for a follow up review to discuss their responses further and to agree any required actions.
Adoption of Ethical Language
A review was undertaken of all Experian’s standard procurement contract templates. The outcome of this review was that all of our standard procurement contract templates now contain the same ethical contractual obligations globally.
Communication of our ethical standards to our employees and training
A global briefing note on Modern Slavery has been issued to all staff via our internal intranet. This highlights both what Modern Slavery is, and how employees should report any suspicions and findings.
Members of the procurement team (both new and existing) have attended a training session on Modern Slavery. This explains the purpose of the act, Experian’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.
We have relaunched our internal confidential helpline, which has been publicised internally along with a specific section on Modern Slavery and some “Frequently Asked Questions”.
Plans for the next financial year
- Review the terms and conditions in our procurement contracts globally against best practice gained from external advisors and our key suppliers and customers, and where necessary, refresh our standard procurement terms and conditions.
- Continue our programme of risk assessing our vendor base.
- Run refresher training with our procurement teams globally and repeat the all – employee communication.
This statement is approved by the Experian Limited Board and signed on its behalf by:
Date: 8 May 2017