GlobalData Plc

Anti-Slavery and Human Trafficking Policy


This policy sets out our expectations and commitments in accordance with the Modern Slavery Act 2015.

GlobalData is a leading data and analytics company, helping 4,000 of the world’s
largest companies make better and more timely decisions thanks to our unique data,
expert analysis and innovative solutions delivered through a single platform.
Our mission is to help our clients decode the future to be more successful and
innovative. Headquartered in the London, we have over 2,000 employees in offices across the globe.

We have zero tolerance for slavery and human trafficking in any part of our business,
including our supply chains. We have a number of policies in place to ensure all our
employees have the right to work and are paid fairly, that we act with integrity and
ethically, and that we have effective measures in place to ensure slavery is not
present anywhere in our business or supply chain.

This includes our Equal Opportunities policy, which encompasses recruitment, promotion,
training, performance management and reward. Our principles of fair treatment and respect
are also applied to our relationships with customers, suppliers, contractors, shareholders and
other stakeholders.

1. Policy statement

1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various
forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all
of which have in common the deprivation of a person’s 6 liberty by another in order to exploit
them for personal or commercial gain. We are committed to acting ethically and with integrity
in all our business dealings and relationships and to implementing and enforcing effective
systems and controls to ensure modern slavery is not taking place anywhere in our own business
or in any of our supply chains.

1.2 We are also committed to ensuring there is transparency in our own business
and in our approach to tackling modern slavery throughout our supply chains,
consistent with our disclosure obligations under the Modern Slavery Act 2015.
We expect the same high standards from all of our contractors, suppliers and
other business partners, and as part of our contracting processes, we include
specific prohibitions against the use of forced, compulsory or trafficked
labour, or anyone held in slavery or servitude, whether adults or children, and
we expect that our suppliers will hold their own suppliers to the same high

1.3 This policy applies to all persons working for us or on our behalf in any
capacity, including employees at all levels, directors, officers, agency
workers, seconded workers, volunteers, interns, agents, contractors, external
consultants, third-party representatives and business partners.

1.4 This policy does not form part of any employee’s contract of employment and
we may amend it at any time.

2. Responsibility for the policy

2.1 The Board has overall responsibility for ensuring this policy complies with our
legal and ethical obligations, and that all those under our control comply with

2.2 The Group HR Director has primary and day-to-day responsibility for
implementing this policy, monitoring its use and effectiveness, dealing with
any queries about it, and auditing internal control systems and procedures to
ensure they are effective in countering modern slavery.

2.3 Management at all levels are responsible for ensuring those reporting to them
understand and comply with this policy and are given adequate and regular
training on it and the issue of modern slavery in supply chains.

2.4 You are invited to comment on this policy and suggest ways in which it might
be improved. Comments, suggestions and queries are encouraged and
should be addressed to the Group HR Director.

3. Compliance with the policy

3.1 You must ensure that you read, understand and comply with this policy.
3.2 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 us or
under our control. You are required to avoid any activity that might lead to, or
suggest, a breach of this policy.

3.3 You must notify Group HR Director as soon as possible if you believe or
suspect that a conflict with this policy has occurred, or may occur in the

3.4 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.

3.5 If you believe or suspect a breach of this policy has occurred or that it may
occur you must notify the Group HR Director as soon as possible.

3.6 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
the Group HR Director.

3.7 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. Detrimental treatment includes dismissal,
disciplinary action, threats or other unfavourable treatment connected with
raising a concern. If you believe that you have suffered any such treatment,
you should inform the Group HR Director immediately. If the matter is not
remedied, and you are an employee, you should raise it formally using our
Grievance Procedure, which can be found in the Employee Handbook on the
GlobalData intranet.

4. Communication and awareness of this policy
4.1 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

4.2 Our commitment to addressing the issue of modern slavery in our business
and supply chains must be communicated to all suppliers, contractors and
business partners at the outset of our business relationship with them and
reinforced as appropriate thereafter.

5. Breaches of this policy

5.1 Any employee who breaches this policy will face disciplinary action, which
could result in dismissal for misconduct or gross misconduct.
5.2 We may terminate our relationship with other individuals and organisations
working on our behalf if they breach this policy.

Anti Slavery and Human Trafficking Policy July 2018: Download as PDF