Modern Slavery Statement

This statement has been published in accordance with the United Kingdom Modern Slavery Act (2015). It sets out the steps taken by sociomantic labs GmbH and its subsidiaries, incl. Sociomantic Labs Ltd (“Sociomantic”) during the financial year ending 28 February 2017 to prevent modern slavery in our business operations and supply chains.

Introduction

Sociomantic has been founded 2009 in Berlin, Germany, and provides online display advertising solutions and services to customers in more than 60 markets, including the United Kingdom.

We are committed to the protection of human rights and we do not tolerate any form of slavery, servitude, forced or compulsory labor, human trafficking, child labor, or any other illegal practices as defined by the United Kingdom Modern Slavery Act 2015 (together hereinafter: “slavery”). We seek to do business only with suppliers who have similar values and ethics as ourselves.

Sociomantic believes that the risk of slavery within its business and supply chain is low, but no business or sector can be considered immune. Sociomantic therefore employs policies and processes to detect and prevent slavery, which includes our code of conduct, and our procurement and supplier management processes.

Procedures Adopted to Assess and Manage Slavery Risk

Aligned with the approach taken by Tesco PLC and its subsidiaries (the “Tesco Group”), we continuously seek to identify supply chains where workers are more vulnerable to slavery and other abuses. As part of this process we consider the types of service provided by our suppliers, the types of labor used (permanent, seasonal, agency), and whether there are known issues in the country of origin of our suppliers or in the country where services are provided.

Sociomantic currently uses up to 100 suppliers, with online display inventory being the biggest category. Most of our suppliers provide services from countries within the European Union and North America. Due diligence assessments are carried out before a supplier is on-boarded, confirming that potential partners operate a legitimate business, are not known as “bad actors”, and are committed to removing illegal practices, including fraud and slavery. Key suppliers undergo quarterly reviews.

Sociomantic has recruitment policies in place, including assessments for confirming eligibility to work in the jurisdiction in question. Most of our colleagues work full time and all colleagues have employment contracts under terms and conditions which are regularly reviewed in line with the applicable employment laws.

Sociomantic seeks to ensure that all colleagues follow its ethical standards. We embedded this in our business via the Sociomantic code of conduct, and internal feedback and review processes.

Sociomantic operates a whistleblowing policy which encourages colleagues to report concerns that relate to either our activities or the activities of a supplier. This includes circumstances that may give rise to an enhanced risk of slavery.

Next Steps

Throughout our current financial year, we will continue to strengthen our approach to managing risks of slavery within our business. Our ambitions include further training on slavery risks to colleagues involved with procurement and supplier management, and reviewing our approach to identify additional steps that we can undertake to combat slavery risks in our supply chains and validate the actions that we and our suppliers have taken to date.

 

THOMAS NICOLAI
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Thomas Nicolai, Managing Director, sociomantic labs GmbH