Slavery and Human Trafficking Statement for the 2018 Financial Year
We have published this statement in accordance with section 54 of the Modern Slavery Act 2015 (the “Act”) on behalf of ZPG Limited and its subsidiaries* (“we”, “us” or “our”). It sets out the steps we have taken during the year to prevent modern slavery and human trafficking in our supply chains and in our business generally.
Our Structure, Business and Supply Chain
We own and operate some of the UK’s most trusted digital platforms including Zoopla, uSwitch, PrimeLocation, Money.co.uk, Bankrate, Property Software Group and Hometrack. We create value by investing in marketing our brands and growing our audience and by developing the best products and platforms to engage our consumers and partners. Consumers increasingly use and rely on our platforms in search of real‐time information about the property and comparison markets. Similarly, property professionals and home services suppliers use our platforms to reach a transaction‐ready audience and market their products and services.
Our supply chains include the following:
• People: recruitment and training services.
• Marketing: media advertising and market research services.
• Professional services: advisory and consultancy services.
• Facilities: maintenance and cleaning services.
• Technology: external data centres, data providers, IT infrastructure, hardware providers, cyber security services and software suppliers.
Our Policies in relation to Slavery and Human Trafficking
We respect human rights and the integrity of individuals. We comply with all relevant laws in the way we run our business.
We have in place a whistleblowing policy which applies to all of our employees, officers, consultants, casual workers and agency workers. This “Speak Up” policy encourages everyone working for us to report any malpractice or illegal acts, including suspicion of modern slavery and human trafficking, or omissions or matters of similar concern by other employees or former employees, contractors, suppliers, partners or advisers using a prescribed reporting procedure.
We engage an external and independent third party based in the UK to provide a reporting facility for individuals to bring areas of concern to our attention in a secure and confidential manner. This facility includes access to a 24/7 confidential whistleblowing telephone line.
We are also committed to conducting business ethically and lawfully and this includes ensuring, as far as possible, that any third parties who act for us share this commitment. The Company’s “Working with Third Parties” policy is in place to help to identify and mitigate risks associated with the third parties who may perform services for or on behalf of us. This includes guidance on undertaking appropriate due diligence on existing or prospective third parties based on identifiable risks.
We have group‐wide template clauses which are included in appropriate contracts which allow contracting parties to formally acknowledge, commit to and abide by applicable anti‐slavery and human trafficking legislation.
Due Diligence and Contracting Practices
We conduct due diligence on our suppliers by requesting information from them (which includes information about the steps they take to ensure there is no modern slavery or human trafficking in their business or supply chains). We keep our due diligence process under constant review, and it was last reviewed and updated in April
We consider suppliers’ responses to our due diligence requests as part of our decision‐making processes when it comes to using new suppliers. We take appropriate action and, if necessary, delay or cancel appointing a new
supplier unless the supplier’s systems and controls are satisfactory.
Assessing and Managing Risk
Due to the nature of our businesses, our supply chains are limited and we operate with only a small number of suppliers.
Nevertheless, we select some of our suppliers based on ethical certifications (some of which – for example, the Fairtrade certification – impose obligations on suppliers to eliminate modern slavery). These suppliers must provide evidence of their ethical certification before we conclude contracts with them.
We also seek contractual assurances from suppliers in relation to modern slavery and human trafficking compliance, particularly where those suppliers operate in, or make us part of, supply chains which present higher risks of modern slavery or human trafficking.
We have continued to provide advice and guidance to the relevant commercial teams with direct responsibility for entering into supplier contracts. We will be introducing specific modern slavery and human trafficking guidance into our induction documents for new joiners.
This statement was approved by the Board of Directors of the Company on 11 June 2019.