This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and sets out the steps the Company has taken during the financial year from 1 January 2017 to 31 December 2017 to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.
Moneysupermarket.com Limited published its first Slavery and Human Trafficking Statement in February 2017 and in the past year we have continued to develop our processes and procedures to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.
Key Areas of Focus for 2017:
- Establishing a procurement team
- Designing and implementing a procurement strategy to support supplier onboarding including due diligence
- Reviewing risk assessments conducted in 2016
Our Organisation and Business
Moneysupermarket.com Limited operates price comparison websites. Our registered office is in Ewloe and we have approximately 380 employees, all of whom are based in the UK.
We operate through our leading brands, MoneySuperMarket and TravelSupermarket and we are committed to providing customers with the services, tools and products they need to save and grow their money.
We are committed to ensuring that there is no slavery, servitude, forced or compulsory human labour, abuse of power over vulnerable individuals, human trafficking or any other form of exploitation as contemplated by the Modern Slavery Act 2015.
Our Supply Chains
Our supply chains include media agencies, online search engines, software suppliers and developers and professional service firms. We do not act as a producer, manufacturer or retailer of physical goods and have no supply chains in relation to such activities.
Our Policies on Slavery and Human Trafficking
As reported in our previous statement, our internal policies include the Moneysupermarket.com Group PLC Anti-Slavery and Human Trafficking Policy where we confirm our zero-tolerance approach to modern slavery and which reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
We also have an Anti-Slavery and Human Trafficking Policy for Suppliers which, as well as setting out our requirements, also includes links to government guidance and factsheets.
These two policies are supported by our Whistleblowing Framework, which encourages and provides clear guidance on raising concerns in confidence relating to any wrongdoings which extends to slavery and human trafficking. All reports will be fully investigated and appropriate remedial actions taken.
Assessment of Modern Slavery Risk within our Supply Chain
In the past year we have continued our focus on Modern Slavery, reviewing risk assessments to determine where the risk of modern slavery and human trafficking lies both within the Company and in its supply chains.
All employees in the Company have their place of work as one of the offices owned or leased by the Company or one of the companies in the Moneysupermarket Group with the exception of a small number (less than five) who work from home. Our HR team oversees the engagement and contracting process for these individuals and articulates the benefits available to employees via handbooks and the Moneysupermarket Group’s intranet.
Suppliers have been assessed in terms of the nature of services they supply to the Company and the geographical risk. These assessments cover the entire scope of our business, encompassing media agencies, online SEM, IT consultancies (including programmers and coders), PR agencies, HR consultancies, building contractors, cleaning companies and other professional service providers. Geographically, most suppliers are based in the UK (or we contract with and make payment to the UK office) with the exception of some SEM and IT licence suppliers. We are aware from due diligence that some of our IT programming/coding suppliers, whilst having a UK office base with whom we have a contract, are part of global organisations and utilise the services of individuals based in countries with emerging economies. Our risk assessment has also highlighted the possibility that in service industries, particularly construction and cleaning, there could be the potential for workers to be put at risk of forced labour. We have categorised our suppliers as Category 1, Category 2 or Category 3 Risk Suppliers.
Due Diligence Processes for Slavery and Human Trafficking
We understand that our biggest exposure to Modern Slavery is with organisations, whilst having a UK office base, who utilise the services of individuals based in countries with emerging economies.
Existing suppliers categorised as Category 1 Risk Suppliers (“Category 1”) and material Category 2 Risk Suppliers (“Category 2”) have been made aware of our zero tolerance of modern slavery and have been asked to sign a confirmation of compliance with the Modern Slavery Act 2015. During 2017 we established a procurement team and have been working on designing and implementing a procurement strategy, with the aim of embedding a robust framework to support supplier onboarding and contract renewals. This will include, as part of our onboarding process, new suppliers in Category 1 and Category 2 being required to complete due diligence questionnaires incorporating questions on modern slavery and their associated policies and procedures. The responses will then be reviewed by the procurement t
eam and, if required, discussed with the Company Secretarial team. New suppliers are also made aware of our zero tolerance of modern slavery and are issued with contracts covering compliance with modern slavery.
In 2016 we have revised our Code of Conduct and trained employees both on the Code of Conduct and our Anti-Slavery and Human Trafficking Policy. Employees are required to complete refresher training on an annual basis. Training is provided to new employees as part of their induction.
Assessment of effectiveness in preventing modern slavery
In order to assess the effectiveness of the measures taken by the Company and the Moneysupermarket Group as a whole we will be reviewing:
- investigations undertaken into reports of modern slavery (including any concerns raised under our Whistleblowing Framework) and remedial actions taken in response; and
- staff training levels.
We will continue to undertake training of employees, particularly those directly involved in engaging suppliers, to ensure they understand and comply with the supplier contract management framework when engaging and managing suppliers.
Date: 20 February 2018
Our Modern Slavery Act Transparency Statement for the financial year ended 31 December 2016 can be found here.