Background

Under the UK Modern Slavery Act 2015, all businesses with over £36m in annual turnover and conducting business in the UK are required to publish а slavery and human trafficking statement. In providing this statement we wish to clearly set out Hyve’s commitment to upholding and implementing high standards of governance and ethical behaviour across its businesses.

We recognise that slavery, forced or compulsory labour and the trafficking of persons for any purpose ("Modern Slavery") is а global issue and we are taking steps to ensure that this is eliminated from our supply chains. Details of the steps already taken, and those to be taken are set out below in this statement.

This is the statement of Hyve Group plc. It covers Hyve and its subsidiaries, by specific reference to Hyve UK Events Limited.

Risk Profile

We have more than 120 events taking place each year, in 14 countries and employ 1,200 people in 17 global offices. We are aware that а number of countries in which we operate have a higher Modern Slavery risk than others (for example, Indonesia, India)*. ln addition, ourevents include certain industry sectors where Modern Slavery may be more prevalent, for example in the construction or manufacturing sectors.
As a result of this, we have taken a number of steps to address our safeguarding responsibilities and create a clear framework across the business to address Modern Slavery.


* The Global Slavery Index 2018: Walk Free Foundation

Our Supply Chain

We work with а large number of suppliers of goods and services, exhibitors, business partners and operational support partners across the globe. We recognise that each of these business “partners” will themselves have their own partners, affiliates, associated entities, subcontracting and other operating relationships.
We also work with sub-contractors and businesses of varying sizes, with our engagements covering variable amounts of time and expenditure in each case. By working in this way, we believe we are able to create long term relationships in the best interests of our customers.

Given our global presence and diverse supply chain, we are aware of the importance of taking both meaningful and lasting action to combat this risk.

Our Existing Framework

We appointed our first full time Group Compliance Officer in May 2019 to introduce a comprehensive compliance programme, addressing matters of global concern such as corruption, as well as Human Trafficking and Modern Slavery. This programme undertook a review and gap analysis across Hyve’s suite of compliance policies and procedures, ultimately resulting in the implementation of new, refreshed policies and re-invigorated training programmes. Furthermore, as part of this compliance programme implementation, arrangements in relation to preventing Modern Slavery have been created, including a new Anti-Slavery and Human Trafficking policy which was approved by the Group’s Risk Committee on 11 September 2019.

A New Policy

In adopting a Group-wide Modern Slavery policy, we are demonstrating a global commitment to address Modern Slavery in our business. It was recognised that the Modern-Day Slavery Statement is a “one-time” communication. By adopting a policy we are able to demonstrate a continuous and ongoing requirement to identify and act on Modern Slavery, which was not an item previously within the Hyve policy framework. The policy gives workers, contractors and other business partners guidance on Modern Slavery and clearly states the measures already taken and yet to be taken by Hyve to tackle Modern Slavery in its business and supply chains. The new policy will be combined with the Group’s updated Whistleblowing Policy and newly implemented Whistleblowing reporting line, which will “go live” in early 2020.

Risk Assessments

We have also assessed our current risks in respect of Modern Slavery, based upon the findings of the Global Slavery Index report and in reference to the following criteria:

  • the Group’s geographical footprint by event;
  • geographical footprint by offices from which we operate; and
  • event sector profile in each country.
There are arrangements in place for concerns in this regard to be raised, anonymously if needed, via our whistleblowing process.

Due diligence

One of the key components of the compliance programme is the delivery of a reliable and repeatable process by which due diligence is undertaken on our third parties. We have purchased new software to allow for such due diligence checks (including capturing adverse media reports for companies, globally, in relation to their practices and any reported prosecutions or sanctions). The software and process are due to be piloted from April 2020.

Actions for Financial Year 2019

Below is our review of Financial Year 2019 objectives.

We said we would put in place a code of conduct for suppliers.

  • After the appointment of the Group Compliance Officer, a detailed assessment of the Group’s compliance framework was undertaken. In addressing a key cultural component, tied to the Group’s values exercise, the initial focus was on the development of an internal Code of Conduct for our employees aligned to our values. This Code contains a chapter dedicated to Human Rights, Anti-Modern Slavery and Human Trafficking.
  • The focus will return to an outward facing code of conduct for suppliers when the internal measures have been embedded.

We said we would conduct a risk assessment of the Group’s material risks based upon Modern Slavery.

  • This assessment has been completed and specific remedial actions are being developed in order to mitigate those risks.

We said we would deliver training to Hyve’s Senior Global, Regional and Local Leadership on Modern Slavery Matters.

  • We are pleased to report that primary awareness presentations, as part of the compliance programme, have been made to several of our overseas offices and a rolling programme of training will continue throughout our Financial Year 2020, tied to the launch of our Code of Conduct.

Actions for Financial Year 2020

In 2020 we will address items not yet concluded from our Financial Year 2019, namely updating, improving and continuing to deliver awareness training and creating a code of conduct for suppliers.
Furthermore, we will undertake the following actions to enhance and reinforce the commitments set out in this statement:

  • periodic reviews of the effectiveness of the steps we have undertaken to date and look for improvements to our practices, whether as a result of additional guidance issued by regulators and Government offices, responding to events occurring around the world, or addressing feedback from those both inside and outside of Hyve;
  • launch the Code of Conduct for our business with a section dedicated to Modern Slavery and Human Trafficking;
  • launch a third party, independently hosted Whistleblowing line for reporting concerns on this subject as well as other matters;
  • select a number of our events in high risk areas, identified through our risk assessment, for visits in the “build up” and “break down” parts of our events process which carry a higher likelihood of incidents occurring;
  • report on the progress of the items to be delivered to the Risk Committee, which holds the compliance programme to account;
  • benchmark our arrangements with businesses of a similar size and geographical reach;
  • specify actions by specific country to help readers understand the context of any actions or steps taken to minimise risks.

Board Approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group slavery and human trafficking statement for the financial year ending 30 September 2019. It was approved by the board on 25 November 2019 and will be subject to annual review.