Slavery and Human Trafficking Statement 2018-19
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 2018.
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 help to give our customers the power to assess, predict and to plan so they may achieve their goals and navigate their world with confidence. Our expertise in data, analytics and technologies, means we give answers, we create coherence and clarity from complexity.
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 16,000 people in 37 countries. The Groups 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 standards. Experian has a Global Code of Conduct which is published at https://www.experianplc.com/responsibility/our-policies/ 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. During the year ended 31st March 2018 no calls were received concerning Modern Slavery in our supply chain.
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 compared with businesses operating in other sectors. Below is a chart which gives an overview of global spend:
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 area, comprising: security guards, caterers and cleaners. In addition, the Group also uses IT contractors. 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:
- Review the terms and conditions in our procurement contracts globally, and where necessary refresh and update the contractual obligations on our suppliers.
- Risk assess our North America supply chain as it relates to Modern Slavery.
- Communicate our ethical standards to all our employees and training of procurement staff.
Risk Assessment of Supply Chain
We have carried out a desktop assessment of our current suppliers in the UK and NA, 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. All new vendors in Brazil are now thoroughly risk assessed as part of supplier onboarding checks.
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.
All members of the global procurement team 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. This training will be provided to our global procurement team again this year, and will continue to be delivered at least once annually.
We have relaunched our internal confidential helpline, this has been widely publicised internally and includes specific reference to Modern Slavery.
Proposed actions for the next financial year
- Review our contractual terms and conditions to ensure they are in keeping with good practice for companies with similar operations.
- Complete further desktop review of our supply chain in Brazil and conclude any required follow up meetings.
- Undertake an on-going programme of supplier reviews focussed on Modern Slavery risks.
- Undertake refresher training with the global procurement teams and repeat the
all – employee communication.
This statement is approved by the Experian Limited Board and signed on its behalf by:
Date: 8 May 2018