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Modern Slavery and Human Trafficking Statement March 2019

This statement is made on behalf of Jellyfish limited pursuant to section 54 (1) of the Modern Salvery Act 2015 (the “Act”) and constitutes our slavery and human trafficking statement.

This statement sets out Jellyfish’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2018 to 31 March 2019.

Jellyfish recognises that it has a responsibility to take a robust approach to preventing slavery and human trafficking and is committed to do so in our corporate activities and supply chains.

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Organisational structure

Jellyfish Group Limited is a limited liability company registered in England and Wales (06227410).

Jellyfish is a global digital partner offering services across PPC, SEO, Social, Analytics, Programmatic display and Video. We employ over 650 personnel and operate globally across EMEA, APAC and the US, with its European HQ in Reigate, RH2 9SS.

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Our approach

We strive to work to the highest professional standards and comply with all laws, regulations and rules relevant to our business.

At UK level, our HR & Legal teams work in conjunction with our procurement functions to help ensure that the aims and provisions of the Act are complied with and to manage any concerns or breaches.

Our recruitment and employment procedures include appropriate pre-employment screening of all staff to determine right to work in the UK. They also receive an HR induction which explains all Jellyfish company policies and confirms that employees are able to contact HR confidentially on any matter of concern, throughout their employment.

We expect all employees to conduct business with honesty and integrity and we have a zero tolerance approach to bribery and corruption.

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Company policy

Jellyfish company policies work to identify and prevent any sort of slavery and human trafficking within its operations. Jellyfish works to maintain high professional and ethical standards and ensures its employees know their role in maintaining these.

All employees are provided with a written contract of employment and are governed by stringent company policies available on the company intranet. These include the Whistleblower Policy, Environmental Policy, Sustainable Procurement Policy, and Anti-Bribery and Corruption Policy.

We do not tolerate any form of modern slavery or human trafficking in any part of our business.

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Due diligence / Risk assessment

Sustainable Procurement is an integrated value in our supply chain management. We seek to trade with suppliers who match and complement our ethical standards and organisational values whilst seeking to minimise the environmental impacts arising from the delivery of their goods or services. We are committed to the following:

  • Mapping the supply chain to assess particular product or geographical risks
  • Evaluating the modern slavery and human trafficking risks of each new supplier
  • Ensuring all new suppliers accept our Code of Conduct policy prior to being on boarded as a supplier
  • Reviewing on a regular basis all aspects of the supply chain
  • Taking steps to improve sub-standard suppliers’ practices
  • Entering into business relationships with suppliers that reflect our organisational values.
  • Work with our suppliers to ensure that they drive ethical and sustainable business practices throughout their organisations

Supplier responses are taken into consideration when short-listing and we make any concerns known to the supplier. Should suppliers fail to live up to our expectations or be unwilling to make any changes we may cease to engage with them.

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Further steps

We will be looking to introduce specific measures to ensure that our obligations under the Act are passed through our supply chain.

These will include:

  • Obtaining contractual warranties through completion of a risk assessment questionnaire to confirm that no slavery is used anywhere in the supplier’s business or by any of the suppliers in its supply chain and that all necessary processes and policies have been put into place to ensure that this remains the case
  • Obtaining a contractual right to request compliance-related information and the right to audit suppliers at our discretion
  • Ensuring risk areas are documented, monitored and taken into consideration in any future contract renewals
  • Assessing supply chain level information and engaging directly with suppliers to set up systems that provide reliable supply chain information, especially for the most at risk jurisdictions
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Relevant e-learning training materials are available to all staff and will be made compulsory for those involved in recruiting and sourcing/managing a supply chain so that they are able to identify risk factors, understand the implications and assist us with implementing the requirements of the Act effectively.

This statement is made pursuant to section 54 (1) of the UK Modern Slavery Act 2015 and constitutes Jellyfish’s slavery and human trafficking statement for the financial year ending 31st March 2019.

This statement was approved by Chris Lee – CFO of the Jellyfish Group and will be updated and reviewed annually.