Modern Slavery Act Statement
This statement, made pursuant to section 54(1) of the Modern Slavery Act 2015, demonstrates our commitment to tackle modern slavery and sets out the approach taken by YouGov plc to understand whether slavery, servitude, forced labour and/or human trafficking (together “Modern Slavery”) exist in our supply chain. This statement demonstrates the actions undertaken to eliminate Modern Slavery during the financial year ended 31 July 2023.
Our Business
YouGov is an international online research data and analytics technology group. Our mission is to offer unparalleled insight into what the world thinks. Our innovative solutions help the world’s most recognised brands, media owners and agencies to plan, activate and track their marketing activities better.
YouGov is headquartered in the UK, with over 1,800 employees worldwide and operating across 59 markets. Our supply chain consists of global suppliers of data, research services and consultancy, computer software and equipment, office supplies, and over 26 million registered members.
The global issues caused by Modern Slavery exist across all sectors and industries. We acknowledge that whilst our industry is considered low risk, it is not entirely without risk, and it is our responsibility to mitigate every potential modern slavery risk. We are a global organisation engaging with suppliers in all countries where we have a physical presence. According to Walk Free’s Global Slavery Index, eight of our offices are in countries with a modern slavery prevalence score above 5 (in ascending order): Poland, Thailand, Mexico, Indonesia, Romania, the Philippines, India, the United Arab Emirates, and Turkey [1].
Where necessary and appropriate, we engage independent contractors [2] and agency workers [3] – for example, to provide additional resource during a busy period. As of 31 July 2023, these staff makeup 1.8% of the global workforce [4]. The business is committed to ensuring that there is no modern slavery in our supply chain or any other part of our operations.
Group Policies & Procedures
Our corporate services teams are responsible for implementation of policies and procedures that support the business in meeting its human rights responsibilities. This includes the following:
- People Team (HR)
- Group Diversity & Inclusion Policy, which includes the prohibition of discrimination and/or harassment
- Group Recruitment Policy and relevant local recruitment processes
- Group Grievance Policy
- Group Bullying and Harassment Policy
- Governance Department
- Group Whistleblowing Policy
- Group Human Rights Policy
- Group Freedom of Association Policy
- Global Code of Conduct & Ethics
- Environmental, Social and Governance (ESG) Roadmap
- Compliance processes to ensure adherence to local and national laws for both YouGov and our suppliers
- Legal processes to ensure fair contractual terms and conditions for both YouGov and our suppliers
- Finance
- Group Procurement Policy, which includes guidelines for supplier selection and defined procurement principles to ensure all appropriate due diligence is conducted
- Payment processes to ensure payments are made in a timely manner and in accordance with all relevant contractual obligations
Expectations for Employees
Our commitment to eradicating modern slavery is emphasised in our employee training and company policies, which promote ethical behaviours. Our employees are required to abide by a Global Code of Conduct & Ethics (“the Code”) which sets out the expectations that YouGov employees will have to meet to ensure our good reputation is carried forward into the future. This includes the expectation that employees will familiarise themselves with the Modern Slavery Act Statement, remain alert to potential violations, and report instances swiftly and appropriately. The Code brings together all our existing policies covering key areas - such as ethical business, our approach to Environmental, Social and Governance (“ESG”) and Speaking Up - and is available for download on our corporate website under Governance.
In 2023, we incorporated modern slavery awareness training into our mandatory Introduction to ESG module for new joiners. In FY24 we will also include this training content in a new mandatory annual ESG Refresher module for all staff. This training includes the International Labour Organization (ILO)’s 11 indicators of forced labour, an overview of YouGov’s approach to mitigating modern slavery risks, and information on how to raise concerns.
Expectations for Suppliers
YouGov expects the same high standards which we set for ourselves from those parties with whom we engage, such as our suppliers and customers. The Company has a Supplier Approval Process to determine a potential supplier’s suitability and alignment with our values. As part of this process, we assess whether they operate lawfully and ethically and take this into consideration when choosing our suppliers.
All key suppliers [5] are required to confirm compliance with our Business Partner Code of Conduct (“the Business Partner Code”), which asks that the supplier has one or more policies to eliminate Modern Slavery from their supply chains. The Business Partner Code includes expectations for the prohibition of modern slavery and child labour; fair and ethical working hours, conditions, and environments; and commitments to freedom of association and non-discrimination. The Business Partner Code is available for download on our corporate website (on the Governance and Compliance FAQ pages).
Board Oversight
YouGov’s Board is committed to delivering high standards of corporate governance and a key element of this is managing the Company in a socially responsible and ethical way. The Company aims to comply with all local laws and regulations applicable to our business; it follows that YouGov is absolutely committed to preventing Modern Slavery in its corporate activities and its supply chain.
Speaking Up
Employees, suppliers, and any other stakeholders are expected to immediately report any suspected incident of modern slavery in YouGov’s direct operations or supply chain. Concerns can be reported to the Group whistleblowing officer, or through an independent third-party organisation as defined in the Group Whistleblowing Policy (further information can be found on our corporate website under Compliance FAQ).
Areas for Improvement
While we have a robust supplier management system in place, we are aware that we can be more proactive in assessing existing suppliers to ensure they remain compliant with our expectations and continue to align with our values and practices. In our latest ESG Roadmap we make a commitment to categorise our supply chain into tiers in FY24 which will help us engage more directly with key suppliers and build greater accountability measures into our supplier management process. We also commit to conducting a risk assessment of Tier 1 suppliers by the end of FY26, and we intend to include modern slavery risks in the assessment. The ESG Roadmap was published in September 2023 and available for download on our corporate website on the Our ESG Approach page.
We will continue to review the effectiveness of all relevant policies and procedures alongside the latest guidance, to ensure they remain fit-for-purpose.
We do not have a corporate key performance indicator in relation to combatting Modern Slavery specifically, as any instance would be a breach of law, our supplier standards and/or our company policies.
We will provide an update on these actions in the revision of our Modern Slavery Act Statement in 2024.
This statement is approved by the Board and signed on its behalf by:
Steve Hatch
CEO
YouGov PLC
14 December 2023
[1] The Global Slavery Index is based on data produced by the International Labour Organization (ILO), Walk Free, and the International Organization for Migration. 86% of the 160 countries scored have a prevalence score under 10. Information on the methodology can be found here: https://www.walkfree.org/global-slavery-index/methodology/methodology-content/#prevalence.
[2] We define ‘contractor’ as an individual providing services direct to YouGov or through their own personal service company (PSC).
[3] We define ‘agency worker’ as an individual providing services to YouGov via a third party (an agency), usually short-term.
[4] Based on 33 individuals in a workforce of 1,820.
[5] ‘Key suppliers’ refers to suppliers that meet the following criteria: all Master Service Agreements; any supplier contract valued at >£10K per annum; and any supplier in the following categories: sample/data provider, software license provider, panel acquisition provider, panel sample provider, corporate sponsor or partnership, supplier has access to YouGov’s personal data, supplier has access to YouGov premises (e.g., office) or systems (e.g., NetSuite). The majority of our suppliers meet one or more of these criteria.
YouGov’s Modern Slavery Act Statement is listed on the UK Home Office online registry, available here.