Modern Slavery Act Statement

July 22, 2020

  1. Our Commitment
    1. Modern slavery is a criminal offense under the Modern Slavery Act 2015. Modern slavery can occur in various forms, including slavery, servitude, forced and compulsory labour, human trafficking, and child labour. All forms of modern slavery have in common the deprivation of a person’s liberty by another in order to exploit them for commercial or personal gain and amount to a violation of an individual’s fundamental human rights.

    2. At Reputation.com, Inc. and its subsidiaries (Reputation.com UK Ltd., Reputation.com Germany GmbH, Reputation.com (Australia) Pty Limited and Reputation.com India Private Limited) (“Reputation.com” or the “Company”) we are committed to providing a zero tolerance policy towards modern slavery, supporting the principles of the Modern Slavery Act and the abolition of modern slavery and human trafficking.
    3. We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in modern slavery.

    4. This policy applies to all individuals working for or on our behalf in any capacity, including employees, directors, agency workers, contractors, consultants, any other third-party representative, and business partners.

  2. Responsibilities
    1. The Managing Director has overall responsibility for this policy and in ensuring that the Company complies with all its legal and ethical obligations.
    2. The People Operations team will have the primary day-to-day responsibility for the implementation of this policy, monitoring its use and ensuring that the appropriate processes and control systems are in place, and amended as appropriate, to ensure it can operate effectively.

    3. Managers are responsible for ensuring that those reporting directly to them comply with the provisions of this policy in the day to day performance of their roles. Managers will ensure that all relevant employees receive adequate training on this policy and any supporting processes applicable to their role.
  3. Compliance with this Policy
    1. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for Reputation.com or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

    2. If you believe or suspect that a conflict with this policy has occurred or may occur in the future, you must notify your manager or the People Operations Team as soon as possible in accordance with the Company’s whistleblowing policy.

    3. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or the People Operations Team.

    4. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.

  4. Communication and Training
    1. Our recruitment and people management policies and processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.

    2. Our zero-tolerance approach to modern slavery is communicated to suppliers, contractors and business partners at the outset of our business relationship with them.

    3. Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

  5. Due Diligence
    1. We will perform due diligence in relation to modern slavery in our business and supply chains and review our existing supply chains.

    2. We will conduct regular risk assessments to determine which parts of our own business and which of our supply chains are most at risk from modern slavery.

    3. We will review the effectiveness of the due diligence and risk assessments performed in relation to Modern Slavery.

  6. Breaches of this Policy
    1. The Company may terminate its relationship with suppliers, contractors, business partners, and organisations working on our behalf if they breach this policy.

    2. If an employee breaches this policy, it may lead to the disciplinary action being taken in accordance with our disciplinary procedure. Serious breaches may be regarded as gross misconduct and may lead to immediate dismissal further to our disciplinary procedure.

  7. Linked Policies
    1. 7.1 Code of conduct policy.
    2. 7.2 Equality and Diversity policy
    3. 7.3 Whistleblowing policy
    4. 7.4 Bullying and harassment policy
    5. 7.5 Recruitment and selection policy.
  8. This statement is signed on behalf of Reputation.com, Inc. by Chris Sundermeier, General Counsel for Reputation.com, Inc., and Anthony Gaskell, Managing Director for Reputation.com UK Ltd.