The UK Modern Slavery Act 2015 (the “Act”) requires companies carrying out business in the UK with turnover over a prescribed threshold (currently £36 million) to publish an annual statement setting out the steps they have taken to ensure that there is no slavery, forced labour or human trafficking in its business and supply chains.
Set out below is UBM plc’s (“UBM”) statement, approved by the UBM Board on 16 February 2017. It covers UBM and companies in the UBM group.
We do not tolerate slavery or human trafficking. We support the principles of the United Nations Universal Declaration of Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work.
Doing Business at UBM, our code of business conduct for UBM employees (http://sustainability.ubm.com/governance), sets out the principles which govern the way our people are expected to behave and links to a series of underlying business conduct-related policies. These include our Code of Labour Standards and Policy on Human Rights. Doing Business at UBM applies to everyone working for UBM, including temporary and contract staff and it applies regardless of location, role or level of seniority.
The Code of Labour Standards sets out the minimum labour standards we expect our businesses, colleagues and our business partners to adhere to. The aim is to achieve or exceed these minimum standards, regardless of location. In the UK, UBM is an accredited Living Wage employer. The Living Wage commitment ensures everyone working for UBM in the UK, regardless of whether they are permanent employees, third-party contractors, suppliers, interns or apprentices, receive at least the Living Wage. Our Code of Labour Standards and the Human Rights Policy confirm our commitment to not using forced or compulsory labour and to forging relationships with partners that uphold the same principles as UBM.
4. Our supply chain
UBM operations are supported by a global supply of goods and services. This supply chain includes both direct and indirect goods and services, such as venue rental and operations, marketing and production services, IT and professional services amongst others. Engagement with third party suppliers takes place across UBM and, as such, we make it a priority through our Code of Business Conduct and its related policies, to ensure that all employees and management are aware of the principles we hold as an organisation and that they should only use third parties who act in a manner consistent with the standards we set in Doing Business at UBM.
The Code of Labour Standards defines the minimum labour standards we expect our businesses, our colleagues and our business partners to adhere to. It recognises that, where we engage third parties to work with us, or on our behalf, we must seek to make these parties aware of our Code of Labour Standards and include compliance as a consideration in our decision to award contracts. Whilst the vast majority of our supply chain represents a low risk of slavery in any form, in assessing geographical risk, we are aware of those territories which might present a higher risk in this respect. We will focus our efforts, amongst other actions, on providing additional guidance to our own employees on what they should be aware of when engaging with third parties in respect to forced labour.
Over the past twelve months we have undertaken an analysis of our global supplier base, which will allow us to identify and assess potential risk areas in our supply chains at a much more granular level. In our Group-wide procurement tenders, we are specifically incorporating terms and conditions on modern slavery and, we expect our major suppliers to sign up to our UBM Code of Conduct, or to confirm their adherence to a similar code with consistent standards. The supplier landscape at UBM is extensive and we are working towards having controls in place which will assist us in gaining further transparency of our supply chain.
Our Anti-Malpractice Policy enables our staff to report any wrongdoing which extends to human rights violations, including modern slavery. All employees have access to Safecall, an independent, confidential reporting service, where concerns regarding unacceptable working practices can be reported. Reports may be made anonymously. All reports are investigated and appropriate action taken.
Doing Business at UBM is available to all employees in several languages on the UBM Hub. Training is given to all new employees and it is a condition of employment that they must uphold the principles set out in our Code by their actions.
7. Performance monitoring and next steps
Our existing Key Performance Indicators (KPIs) focus on the training of our employees across the organisation. We monitor completion rates of the Code of Business Conduct related e-learning modules, including Anti-Bribery & Corruption and Health & Safety and the outcomes of all investigation of complaints received under our Anti-Malpractice Policy. We will continue to review our KPIs and will add to these as appropriate.
8. Board approval
This statement was approved by the Board of UBM plc and its subsidiaries covered by the Act on 16 February 2017 and will be subject to annual review.
Chief Executive Officer
Download UBM plc Modern Slavery Statement