In May 2019 we introduced a comprehensive compliance programme, addressing matters of global concern such as corruption, as well as Human Trafficking and Modern Slavery. This programme concluded in October 2020. It 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 were created, including a new Anti-Slavery and Human Trafficking policy which was approved by the Group’s Risk Committee in September 2019.
Anti-Slavery and Human Trafficking Policy
Our Group-wide Anti-Slavery and Human Trafficking Policy demonstrates a global commitment to address Modern Slavery in our business. The policy gives workers, contractors and other business partners guidance on Modern Slavery and clearly states the measures in place to tackle Modern Slavery in its business and supply chains.
Overarching this particular policy is the Group’s new global Code of Conduct, which operates as an umbrella policy for a number of new global policies, including, but not limited to the Anti-Slavery and Human Trafficking Policy. Furthermore, the policy is supported by the Group’s updated Whistleblowing Policy and its newly implemented 24-hour multi-platform Whistleblowing reporting line, which was launched in 2020 and which operates across the Group in multiple languages.
In 2019 and 2020 we 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.
Code of Conduct
In March 2020 we launched our global Code of Conduct which expressly includes a section dedicated to Modern Slavery. This Code acts as an umbrella to other key policies central to the Group’s values and operations, namely: whistleblowing, bribery and corruption, conflicts of interest, competitive behaviour, bullying and harassment in the workplace, discrimination, health and safety, data protection, share dealing and sanctions.
Traiing on the Code and other Group policies was implemented to ensure that our employees understand our obligations when it comes to operating in a fair and ethical way.
The next steps
The COVID-19 pandemic has led to a pause in our event scheduling, however, our commitment to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business remains. As the impact of the COVID-19 pandemic lessens and our business returns to normal we will undertake the following actions to enhance and reinforce the commitments set out in this statement:
- our operational and health and safety teams (whether internal or external as applicable) will select a number of our events in high risk areas for visits and assessment in the “build up” and “break down” phases of our events process which carry a higher likelihood of incidents occurring; and
- we will review and investigate any reports made pursuant to the Anti-Slavery and Human Trafficking Policy or under our whistleblowing reporting processes.