Anti-Slavery and Human Trafficking Statement
Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.
At Validity, we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year 2021.
Our business and supply chains
Validity, Inc. is a leading provider of data quality and marketing analytics software. We have offices across the United States and in Canada, UK, France, Brazil, and Australia. We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier’s reputation, respect for the law, compliance with health, safety and environmental standards, and references.
To date, we haven’t been made aware of any allegations of human trafficking/slavery activities against any of our suppliers. Should we become aware of any allegations in the future, then we will act immediately against the supplier and report it to the authorities.
Validity has the following policies and processes for identifying and preventing slavery and human trafficking in our operations:
- Policy Against Human Trafficking: Human Trafficking and Child Exploitation – Validity condemns all forms of human trafficking and the commercial sexual exploitation of children. Validity supports every person’s right to safety and security, especially children, who are most vulnerable. The protection of children from sexual exploitation is a moral imperative, and socially responsible policies and practices must reflect this principle. Validity will strictly comply with all applicable laws and regulations regarding the prevention of human trafficking and the commercial sexual exploitation of children and will cooperate with law enforcement authorities to address any such instances of exploitation of which Validity or its employees have become a party to.
- No employee may:
- Use or allow the use of any of Validity’s facilities, resources or equipment (including Validity’s computers and networks) for the viewing, storage, distribution, promotion or other use of materials in which children are depicted as engaging in any sexual act or are otherwise made an object for prurient interests;
- Enter into, on behalf of Validity or otherwise, any business relationships or any other arrangement with any organization which the employee has reason to believe participates in any way in human trafficking and the commercial sexual exploitation of children; or
- Use or allow the use of images or concepts that sexually exploit children.
- All employees must be vigilant and immediately report to Validity’s Chief Compliance Officer, as appropriate, all situations that come to their attention in our premises or businesses where human trafficking and the commercial sexual exploitation of children is suspected or appears to be intended. Under no circumstances may Validity’s funds, property (including electronic devices and supported technology) or personnel be used to further or support activities that participate in human trafficking and/or child exploitation. Validity does not recruit child labour and supports the elimination of exploitative child labour. We will cooperate with law enforcement authorities to address any such instances of exploitation of which we become aware.
- Whistleblowing Policy – we encourage all employees, customers, and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. We provide a confidential helpline to protect the identity of whistle-blowers.
- Code of Conduct – our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
Supplier due diligence
Validity conducts due diligence on all new suppliers during on-boarding and on existing suppliers periodically. This includes:
- Assessing risks in the provision of particular services
- Reviewing the suppliers’ health and safety standards, labour relations and employee contracts
- Requiring improvements to substandard employment practices
- Sanctioning suppliers that fail to improve their performance in line with our requirements
We require all suppliers to:
- Not use any form of forced, compulsory or slave labour
- Ensure their employees work voluntarily and are entitled to leave work
- Ensure they provide each employee with an employment contract that complies with local laws and contains a reasonable notice period for terminating their employment
- Ensure they don’t require employees to post a deposit/bond and don’t withhold their salaries for any reasons
- Ensure they don’t require employees to surrender their passports or work permits as a condition of employment
Validity raises awareness of modern slavery issues by training its employees regarding:
- Our commitment in the fight against modern slavery
- Red flags for potential cases of slavery or human trafficking
- How employees should report suspicions of modern slavery
In addition to the awareness programme, Validity provides training to its employees regarding:
- Various forms of modern slavery in which people can be held and exploited
- The prevalence of the problem and the potential impact to our organisation
- How employees can identify the signs of slavery and human trafficking, including unrealistically low prices
- How employees should respond if they suspect slavery or human trafficking
- What external help is available for the victims of slavery
- What steps Validity will take if a supplier fails to implement anti-slavery policies or controls
- An attestation from employees that they will abide by Validity’s anti-slavery policy
Validity has defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organisation and supply chain. These include:
- The progress of employee training initiatives
- The number of reports that have been made by our employees indicating their awareness of and sensitivity to the issue of modern slavery
- The findings of any investigations and resolutions to any reported issues which displays how we are addressing modern slavery and human trafficking
This statement has been approved by senior management and is effective August 26, 2021. It replaces any previous statements on the subject and remains in effect until updated or replaced by a future statement.