Modern Slavery Act Transparency Statement

Modern Slavery Act Transparency Statement

The statement below sets out action taken by Hibu to understand and mitigate potential modern slavery risks related to its businesses and put in place steps that are aimed at ensuring there is no slavery and human trafficking in its own business or in its supply chain.

Hibu Group Slavery and Human Trafficking Statement September 2017

Introduction

Hibu is an international business with customer facing operations in the US and UK. Operating under a range of brands, our products (digital and print) are famous for helping our merchant customers get found by consumers. Our digital product range includes on-line directories, websites, search and display products and analytic tools. 

Our supply chain extends beyond the countries in which our customers are located. In particular, certain customer services and production facilities are located in India and the Philippines. 

Hibu prides itself on its long-held commitment to ethical business practices. As such, we fully support the objective of the United Kingdom’s Modern Slavery Act 2015, which requires businesses to publish on their website an annual disclosure detailing steps taken to address the possibility of slavery and/or human trafficking in their supply chains. 

A codified approach

The Hibu Code of Ethics is the foundation stone of our approach to ethical business. Its core principle is that everyone has the right to be treated with honesty and respect, and to work in a safe and healthy environment. Specifically, as regards suppliers, the Code states:
Suppliers should ensure their workers are treated fairly and with respect. For example, they should comply with working hour limits and minimum wage guidelines and not employ child labour. Our suppliers should ensure working conditions are healthy and safe………. 
Every new employee to Hibu is trained in our Code of Ethics and our Compliance Team is responsible for ensuring that this training is refreshed on a regular basis.

In addition, we require all our Suppliers to commit to a separate Code of Ethics for Suppliers and to promote the same high standards through their supply chains.

The supplier code is based on statutory requirements and internationally recognised standards set out in the UN Universal Declaration of Human Rights and the International Labour Organisation Conventions.

It specifically provides that suppliers will not employ any person below the minimum legal age for employment and will take particular steps to safeguard the interests of any workers under the age of 18. In addition, it sets strict standards as regards forced labour, working hours, minimum wage, zero discrimination, freedom of association and health and safety.

Monitoring and compliance

Compliance with Hibu’s supplier code is a mandatory requirement for working with us. From time to time our Compliance and Procurement teams will carry out assessments to verify compliance. Our suppliers are all on notice that Hibu reserves the right to terminate their contracts in the event of non-compliance. All our suppliers are expected to comply fully with all national and local laws and regulations.

In the past 12 months, in addition to training and compliance activity, the specific topic of slavery and human trafficking has been considered and given due attention at main board level and at each operating company level. Specifically, each management team has considered its supply chains and conducted assessments of the level of risks relating to slavery and human trafficking in their operations across the US and UK.

Enquiries were carried out by our Compliance Team at the supplier level, which involved contacting all perceived “higher” risk suppliers and requiring them to confirm that they comply fully with the Modern Slavery Act.

No facts or circumstances came to light through the above process that have caused us to be concerned about the existence of slavery and/or human trafficking in the Hibu group and its supply chain.

In addition to ongoing training and compliance activities as detailed earlier in this statement, our Compliance and Procurement teams have carried out a full Code of Ethics Audit at a number of key suppliers – including site visits in India and the Philippines. These compliance audit site visits confirmed that Hibu’s supplier operations in India and the Philippines have robust and comprehensive procedures in place to prevent modern slavery, including regular internal and external independent audits and strict recruitment processes and monitoring throughout their supply chains.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's modern slavery and human trafficking statement for the financial year ending 31st March 2017 as approved by the Board on 25 September 2017. 

Signed on behalf of the Board 

David Sharman 
Group CEO
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