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Modern Slavery and Human Trafficking StatementActualizados February 2021
This statement is filed by Trustpilot A/S pursuant to section 54 (1) of the Modern Slavery Act 2015 (the “Act”) and constitutes our Group slavery and human trafficking statement for the financial year 1 January 2020 to 31 December 2020.
We recognise that we have a responsibility to take a zero tolerance approach in preventing slavery and human trafficking, and are committed to ensure there is no such slavery or human trafficking in our corporate activities, supply chains and any other part of our business. We are proud of the steps that we have taken to understand potential risks and combat modern slavery within our business and supply chain to date.
Trustpilot is a leading global review platform, which provides a place where businesses and consumers can gain insights and collaborate. Consumers can share feedback about any business with a website and review feedback left by other consumers. The platform not only facilitates better purchasing decisions, but also gives consumers the opportunity to be heard, as they can recommend businesses, products and services based on their experiences. Our mission is to be a universal symbol of trust.
Organisational structure & supply chains
Trustpilot A/S (our parent company) is a limited liability company registered in Denmark. As of February 2021, we employ over 700 staff and operate globally across UK, EMEA, APAC and the US. Subsidiaries which form part of the Trustpilot Group and are covered by this statement include:
- UK: Trustpilot Limited
- Lithuania: Trustpilot UAB
- Germany: Trustpilot GmbH
- United States: Trustpilot, Inc.
- Australia: Trpilot PTY Limited
As a SaaS company, our people, expertise, and intellectual property rights are our business, and as a result, we have a relatively small supply chain. Although we engage with suppliers for a range of services, the majority of our suppliers provide us with IT hardware, network services, and software. Our business model therefore does not carry with it a high level of slavery risk.
We strive to work to the highest professional standards and comply with all laws, regulations, and rules relevant to our business.
Our HR and 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 Modern Slavery Code of Conduct sets out the standard of conduct for customers, contractors, and vendors working with us. It is publicly available on our website.
Our recruitment and employment procedures include appropriate pre-employment screening of all employees, such as right to work checks and reference checks. New employees also receive an HR induction and new hire training which explains company policies and confirms that employees are able to contact HR or our whistleblower email account confidentially on any matter of concern, throughout their employment.
We are also committed to paying the Real Living Wage to our employees and contractors across all our locations in the UK.
We expect all employees to conduct business with honesty and integrity and we have a zerotolerance approach to bribery and corruption, as set out in our Global Anti-Bribery Policy.
In our Code of Ethics, we make it clear that we’re committed to conducting our business with the highest ethical standards. Trust, transparency, and integrity are values that are important to us. We also state that we want to build a trustworthy platform. This means we expect the people who work for us, and those we do business with, to always act with integrity, build trust and promote transparency, and make decisions that reflect strong ethics.
A part of this means that we avoid doing business with companies that are a “bad fit”. A bad-fit company does not share the same values and core beliefs as us. Our Bad-Fit Policy sets out what types of companies we don’t want to sell to, sign up, or otherwise work with at Trustpilot. We also explain who employees should notify if they become aware of a (potential) bad-fit company, what the process will be to determine whether the company is a bad fit for Trustpilot, and what measures we’ll take to stop any active communication or cooperation with bad-fit companies.
Our company policies work to identify and prevent any sort of slavery and human trafficking within our operations. We work to maintain high professional and ethical standards and ensure our employees know their role in maintaining these.
All employees are provided with a written contract of employment, including Trustpilot’s Code of Ethics, and are governed by company policies available on the company intranet. These include the Code of Ethics, Contract Approval & Signing Policy, Global Anti-Bribery Policy, Non-Discrimination & Anti-Harassment Policy, Speaking Up Policy, and Bad-Fit Policy.
Our Modern Slavery Code of Conduct is publicly available on Trustpilot’s website for all vendors, customers and contractors to access.
Due diligence/Risk assessment
We seek to work with customers, contractors, and vendors who match and complement our ethical standards and organisational values.
To identify sectors and categories with high modern slavery risks, we have used the following indicators that are generally known to increase risk likelihood:
- Reliance on low-skill workforce.
- Reliance on migrant workforce.
- Presence of children.
- Hazardous or undesirable work.
- Based in a country that experiences high levels of corruption, weak governance, and poor enforcement of human rights.
Due to Trustpilot being an online-based business, our main vendors consist of those who provide online-based services to facilitate our platform, and general advisory services from reputable companies. Based on the above factors, we therefore consider the risk of modern slavery in our supply chain to be low.
However, we recognise that there is no room for complacency and will continue to work to enhance our policies and procedures and measure awareness within our business. In 2020, we took preventative action to combat modern slavery risks in our supply chain by creating a specific procurement function and updating our Terms of Business. We continue to:
- Undertake due diligence when short-listing our vendors and contractors.
- Review on a regular basis the vendors and contractors we use.
- Enter into business relationships with vendors that reflect our organisational values.
- Ensure that any vendor or contractor we deem to be medium to high risk based on their geographical location have an ethical treatment clause in the vendor contract they provide us. This is to ensure that the work environment and conditions they provide to their employees meet standards under our Modern Slavery Code of Conduct.
Should a vendor or contractor fail to live up to our expectations or be unwilling to make any changes, we may cease to engage with them.
We recognise the challenges presented by the Covid-19 pandemic and continue to monitor our risks during this period. We are committed to prioritizing the health and safety of our employees. In March 2020, we implemented a full contingency plan of closing all offices and requiring all staff working from home to prevent the spread of Covid-19. We also established a Covid Committee which has met regularly throughout the Covid crisis and liaises with the Corporate Services Team for advice on regulations affecting the workplace across the Group. With regard to our supply chain, our assessment is that risks relating to modern slavery have not increased during this period, given the nature of our business and the geographical location of the majority of our vendors.
We will be looking to introduce specific measures to ensure that we continue to reduce the risk of modern slavery within our supply chains.
These will include:
- Obtaining a contractual right to request compliance-related information and the right to audit vendors at our discretion.
- Ensuring risk areas are documented, monitored, and taken into consideration in any future contract renewals.
All new employees receive an HR induction and new hire training which explains relevant company policies. We look to implement compulsory modern slavery specific training in the near future to all employees involved in the recruitment of staff and procurement of vendors 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 was approved by Trustpilot A/S Board of Directors on 11 February 2021.