Modern Slavery Policy

17th May 2024

Policy Information

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our modern slavery and human trafficking statement. This statement is made on behalf of Credera, and each of its subsidiaries listed at the end of this statement, (together “we,” “our,” “us”). We foster a culture of collaboration and focus on investing in our people, protecting the environment and giving back to the communities in which we operate. We have a zero-tolerance approach to any form of modern slavery and are Id to establishing effective systems and controls to safeguard against any form of modern slavery or human trafficking in our supply chain.

Date of Next Review 17/05/2025

Introduction

This Statement is Credera’s Modern Slavery Statement (the “Statement”) and covers the period of 1st January 2024 to 31st December 2024. Credera is committed to respecting human rights and believes there is no place for modern slavery within the operations of any ethical business. We are joining the challenge to combat modern slavery by working to guard against this practice in our own supply chains and operations. Modern slavery refers to cases of serious exploitation, including where offenders use coercion, threats, or deception to exploit victims and undermine their freedom. Modern slavery impacts men, women and children and includes situations where individuals are forced to work against their will under threat. This Statement applies to Credera and any listed subsidiary entities. The Statement has been produced in accordance with Australia’s Modern Slavery Act (2018), and the United Kingdom’s Modern Slavery Act (2015). This Statement outlines the steps Credera has taken to identify and develop a strategy designed to better manage our exposure and ensure continuous improvement of the risks of modern slavery to its supply chain and business operations.

About Credera

Credera is a consulting firm focused on strategy, transformation, cloud, data, and engineering. Our more than 700 consultants across the globe partner with clients ranging from FTSE 100 companies to large government departments. Credera’s European arm, previously known as DMW Group, was founded over 30 years ago and believes the most effective solutions are created through genuine collaboration with a sharp focus on pragmatism. We care deeply about building trusted relationships with our clients to deliver tangible business results. We strive to work to the highest professional standards and comply with all laws, regulations, and rules relevant to our business. This statement is made on behalf of Credera, and each of its subsidiaries listed at the end of this statement, (together “we,” “our,” “us”). We foster a culture of collaboration and focus on investing in our people, protecting the environment and giving back to the communities in which we operate. We have a zero-tolerance approach to any form of modern slavery and are committed to establishing effective systems and controls to safeguard against any form of modern slavery or human trafficking in our supply chain.

Operations, Structure & Supply Chains

Group Structure

Credera’s Business and Modern Slavery Risks 

Our Supply Chain 

During 2020, we undertook a review of potential risks of modern slavery practices across our operations based on guidance as provided by the UK Government and the Commonwealth Government's Department of Home Affairs. Our key suppliers are technology service providers and software service providers. Modern forms of slavery are not typically prevalent in the industries in which these suppliers operate. We expect the same high standards as those to which we hold ourselves from those businesses with which we work. We believe the nature of our work, our supply chains, and their industries to be low risk in terms of modern slavery. Outside of our key suppliers, we have identified potential risk areas for our business. Geographic risk may arise in situations where we have directly engaged with overseas service providers operating out of developing countries. Each year, we make significant investments in purchasing new laptops with the understanding that laptops, as electronic products, have the potential to be exposed to modern slavery in their manufacturing process. Also, certain types of services that generally involve lower wages and manual labour, such as cleaning, may also give rise to modern slavery risks.

Our Policies 

Our corporate responsibility strategy, codified in the Omnicom Group Code of Business Conduct, aims to improve the impact of our business on society and we are committed to ensuring that there is no modern slavery in any part of our supply chains or in any part of our business.  

Our Supplier Code of Conduct reflects our commitment to acting ethically and with integrity in our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our supply chains. A copy of our Supplier Code of Conduct can be supplied upon request.  

Our actions and findings in addressing the various risks of modern slavery practices in our business have been as follows: - 

1. we have continued to update existing websites so that they contain the latest copy of our Modern Slavery Act statement and Supplier Code of Conduct. 

2. we have identified that modern slavery is not prevalent in the industries of our key suppliers, and that our suppliers are not located in markets where there is a high risk and level of exposure to modern slavery. 

3. we have taken a risk-based approach in carrying out our zero-tolerance stance towards modern slavery. This risk-based approach requires various procedures to be performed in identifying suppliers who may have a higher risk profile with regards to modern slavery; and 

4. we have performed an annual analysis of overseas suppliers engaged throughout the year and have assessed whether any are based in high-risk countries. We have identified products that we have purchased throughout the year (e.g., laptops) that may have a higher risk of modern slavery in their manufacture. We have identified services that we have engaged in the UK and Australia that are generally low paid and involve manual labour. For these suppliers that have been identified as having a higher risk of modern slavery, we have assessed our relationship with the supplier. Where we possess significant leverage with the supplier, we have requested detailed and ongoing reporting of financial data from the supplier to ensure there is no indication of modern slavery within their work force. 

How Credera Assesses and Addresses Modern Slavery Risks 

Assessing Modern Slavery Risks, Ongoing Monitoring and Consultation 

To assess the ongoing effectiveness of its measures to combat modern slavery, Credera takes the following steps: - 

1. we audit our policies relevant to modern slavery on an annual basis to assess performance against established industry benchmarks and update them as required. 

2. we conduct periodic reviews of our organisation and supply chain structures and assess whether there are any changes to the level of risk of modern slavery; and 

3. we consult with Credera entities as part of its ongoing assessment and for the purposes of determining any further steps required to address the risks of modern slavery within their organisations and supply chains. 

Code of Business Conduct and Ethics 

Our corporate responsibility strategy, codified in the Omnicom Group Code of Business Conduct, aims to improve the impact of our business on society and we are committed to ensuring that there is no modern slavery or human trafficking in any part of our supply chains or in any part of our business.  Our new Supplier Code of Conduct reflects our commitment to acting ethically and with integrity in our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place anywhere in our supply chains. A copy of our Supplier Code of Conduct can be supplied upon request.  

Ongoing Monitoring of Modern Slavery Risks 

Our steps to implement this new Supplier Code of Conduct are ongoing and are as follows:  

1. communicating the new Supplier Code of Conduct to our suppliers. 

2. aiming for our new supplier contracts to contain express warranties and indemnities regarding compliance with the Modern Slavery Act 2015 and our new Supplier Code of Conduct; and  

3. taking a zero-tolerance approach to suppliers who fail to comply with our new Supplier Code of Conduct, other relevant policies, and procedures and with applicable laws.  

We continue to review our policies and processes to go beyond basic social and environmental regulations and to ensure the highest standards in our supply chain, as expected by our customers and the companies with which we work.  We understand that this is a continual process in our efforts to ensure that no form of forced labour or slavery is present in our business or our supply chain. We continue to work on:  

1. identifying relevant members of staff who would benefit from anti-modern slavery and anti-human trafficking training and guidance, so that training and guidance may be provided; and  

2. identifying the risks and level of exposure within our supply chain and managing such risks responsibly.  

Where the supplier produces an annual statement on modern slavery, we have obtained a copy of their statement to assess if there is any indication of modern slavery in their supply chain. And where the supplier does not have a statement on modern slavery, we have requested that the supplier complete a modern slavery questionnaire explaining what they are doing to assess and address their risks of modern slavery. 

Reporting Concerns related to Modern Slavery 

Any Credera employees, associates, or contractors are encouraged to report any suspicious activity which may be considered to fall within the realm of Modern Slavery. All employees, associates, and contractors undertake Annual Mandatory Training to build and maintain awareness. To report any concern, please contact via email to legal.support@credera.co.uk

Training related to Modern Slavery 

Credera staff, associates and business partners providing resources to Credera must undertake Modern Slavery Mandatory training at Induction and Annually thereafter. Training is monitored for compliance and a “Real Time” training dashboard is used to validate/evidence compliance and is used as a “Key Performance Indicator.”

Resources used for completing this policy 

In completing this policy, several tools/resources have been used to verify “best practice”, these tools include: - 

Credera Values 

Integrity  

We seek honesty and consistency with what we say and pledge our integrity with our actions. We do the right thing, even when no one is watching and no matter the cost. 

Tenacity  

We are focused on driving a programme from strategy to successful completion. We address obstacles head-on with grit, curiosity, and a deep drive to make an impact. 

Excellence 

We never try to “sell” a client on a perfect plan or solution. There is no such thing. But we do take time to understand the real-world issues and apply our experience to achieve remarkable results. 

People First 

We treat each person with value and care. We are kind with our words and actions, seeking understanding, so that everyone is authentically known. Individual differences bring strength. 

Humility 

In every decision we consider our clients’ and colleagues’ interests as more important than our own. When we are wrong, we own our part, learn from our mistakes, and work to rebuild confidence and trust. 

This statement constitutes the modern slavery and human trafficking statement for Credera Limited. 

More Information 

For more information on what a transparent supply chain is, please see the UK Government Legislation related to Transparency in the Supply Chain. For the UK Modern Slavery Act 2015 in its entirety, please see the UK Modern Slavery Legislation. Link to the published Credera Modern Slavery Statement on the Credera Public Facing Website is located at: - Modern Slavery Statement (credera.co.uk)

Omnicom Group – Supplier Code of Conduct 

Introduction 

Omnicom Group Inc. and each of its subsidiaries (hereinafter collectively referred to as “we,” “our,” “us”) are committed to achieving a standard of excellence in every aspect of our business. We always strive to work to the highest professional standards relevant to our business. Our corporate responsibility strategy aims to improve the impact of our business on society. We expect the same high standards from those businesses with which we work. A reliable and ethical supply chain is critical for our business. Consequently, we expect our suppliers to conduct their business activities ethically and responsibly, with integrity, honesty, and transparency. We require that all members of our supply chain endorse our values by operating ethically. 

At a minimum, we expect you and each of your subsidiaries, including your respective employees and agents (hereinafter collectively referred to as “you” and “your”), to meet the standards and promote the principles outlined in this Supplier Code, and we expect you to hold your own suppliers to the same standards. 

This Supplier Code is not exhaustive and should not be used to prevent or discourage companies from exceeding these standards. 

Principles of Supplier Conduct 

1. Anti-Discrimination 

You shall not discriminate against any employee based on sex, race, religion, sexual orientation, gender identity and/or expression, national origin, age, disability, pregnancy, marital status, or any other legally protected characteristic, in hiring or other employment practices.  

2. Anti-Harassment and Abuse 

You shall commit to a workplace free of harassment and abuse and shall not threaten workers with, or subject them to, harsh or inhumane treatment. You shall uphold the human rights of workers and treat your workers with dignity and respect. You shall ensure that workers have a mechanism to report grievances and that your business encourages and facilitates open communication between management and workers. 

3. Underage Workers 

You shall ensure that no underage worker is used in the production or distribution of your goods or services. You shall employ only workers who meet the applicable legal minimum working age, except that in no event shall you employ any person who is under the age of 16 even if local law permits otherwise. 

4. Working Hours, Wages and Benefits 

You shall set working hours, wages (including but not limited to shift pay and other allowances) and over-time pay in compliance with applicable laws. Your workers shall be paid at least the minimum legal wage. All deductions from wages must be lawful and, where applicable, with the express permission of the employee. 

5. Freedom of Association 

You shall freely allow workers lawful rights to associate with others, form and join organizations of their choice, and bargain collectively as permitted and in accordance with all applicable laws and regulations, without discrimination, retaliation, or harassment. 

6. Employment Status 

You shall employ workers who have complied with all relevant immigration regulations and who lawfully live and work in the country in which you operate. You shall ensure that all workers provide satisfactory proof of identity to you and that employment by you of your workers does not breach any laws, rules, or regulations. 

Your employees must be free to leave their employment after giving reasonable notice and shall not be required to lodge deposits or payments (in cash or other kind) with their employers. 

7. Health and Safety 

You shall provide and maintain a safe work environment and integrate sound health and safety management practices into your business. You shall have a system for workers to report health and safety incidents without fear of reprisal, as well as a system to investigate, track, and manage such reports, and implement required corrective action. You shall obtain, keep current, and comply with all required laws, regulations, health and safety permits, licences, and consents. 

8. Whistleblowing 

You shall have clear policies and procedures in place so that workers may report concerns about wrongdoing in their workplace without being victimized, dismissed, or otherwise retaliated against. You shall also comply with all other applicable laws in relation to whistleblowing. 

9. Prevention of Modern Slavery and Human Trafficking 

You shall take reasonable steps to ensure that modern slavery and human trafficking is not taking place in your supply chains or in any part of your business. Within 20 days of request, you shall provide to us a modern slavery and human trafficking report setting out the steps you have taken to ensure that modern slavery and human trafficking is not taking place in any of your supply chains or in any part of your business. This may include, to the extent relevant, information concerning: 

(a) your business structure and supply chain. 

(b) the policies you have adopted to ensure there is no modern slavery, including human trafficking, forced or indentured labour, slavery, or servitude, within your business. 

(c) the training and other measures used to ensure appropriate policies and procedures are applied. 

(d) the due diligence and monitoring conducted by your business to understand the relevant risk areas and confirm that no such behaviour is occurring. 

(e) a confirmation that no modern slavery issues have been identified in your business or supply chain in the last year. 

(f) to the extent any potential issues concerning modern slavery (including human trafficking, forced or indentured labour, slavery, or servitude) have been identified within your business, the circumstances surrounding those issues and the steps you have taken to remedy such issues; and/or 

(g) documents evidencing the information provided in relation to the matters set out in this paragraph 99. 

10. Environment 

You shall develop, implement, and maintain environmentally responsible business practices. You shall carry out your operations with care for the environment and comply with all applicable environmental laws and regulations. 

11. Compliance with Law 

Your business activities shall comply with all applicable laws and regulations in the countries and jurisdictions in which you operate. 

12. Anti-Bribery 

You shall not engage in corruption, extortion, embezzlement, or bribery to obtain an unfair or improper advantage on our behalf. This means that you shall not provide or receive anything of value to obtain an improper business advantage or favourable treatment or exert undue influence, including offering, giving, asking for or taking any form of potential bribe or kickback. 

This prohibition extends to payments and gifts of cash or in kind, made directly or through others and includes a prohibition on facilitation payments intended to expedite or secure performance of a routine governmental action such as obtaining a visa or customs clearance, even in locations where such activity may not violate local law. You shall abide by all applicable anti-corruption laws and regulations of the countries in which you operate, including the US Foreign Corrupt Practices Act, the UK Bribery Act 2010 and applicable international anti-corruption conventions. 

13. Disclosure of Information 

You shall accurately record information regarding your business activities, employment, health and safety, and environmental practices and shall disclose such information, without falsification or misrepresentation, to all appropriate parties and as required by law. You shall maintain accurate financial books and business records in accordance with all applicable legal and regulatory requirements and generally accepted accounting practices. 

14. Information Security 

You must comply with applicable data privacy laws (e.g., GDPR, CCPA) and must protect the confidential and proprietary information of others, including personal data, from unauthorized or unlawful processing, access, destruction, use, modification, and disclosure, and against accidental loss or destruction, or damage through appropriate technical and organizational measures including physical and electronic security procedures. You also are expected to take the necessary information security measures, for both computer systems and portable electronic devices, to protect against malware and unauthorized disclosure of any proprietary 

information. You are responsible for tracking new data privacy laws and modifications to current laws. 

15. Risk Assessment and Management 

You shall develop and maintain a process to identify employment and human rights, health and safety, environmental, business ethics, and legal compliance risks associated with your operations, determine the relative significance of each risk, and implement appropriate procedures and controls to minimize the identified risks. 

Conclusion 

This Supplier Code is intended to promote a culture among our suppliers that complies with both the letter and the spirit of all applicable laws, rules, and regulations. You should refer to the principles set out in this Supplier Code when ethical and compliance issues arise. Each of the principles in this Supplier Code is fundamental to how we do business. However, this Supplier Code cannot anticipate every possible instance in which an ethical issue may arise, and so it aims to reinforce the ethical and responsible way in which we require you to conduct your business and the integrity, honesty and transparency which is required in your operations.