Modern Slavery Statement

INTRODUCTION

First Databank UK Ltd (“FDB”), recognises its legal and moral obligations to comply with the Modern Slavery Act 2015 and is committed to operating its business responsibly.

The Modern Slavery Act requires companies to explain on an annual basis how they address the issue of modern slavery and human trafficking in their global supply chains. FDB is not caught by the obligation to produce a statement but has produced this information in recognition of our commitment to comply with the spirit of the Modern Slavery Act

This statement sets out the steps FDB has taken to ensure that modern slavery and human trafficking are not taking place in our supply chain or any part of the business and to eliminate as far as is possible the risk of modern slavery and human trafficking taking place within our organisation.

OUR SUPPLY CHAINS

FDB is committed to ensuring that all our products and services are responsibly sourced. We procure services from a wide variety of providers and our supply chains include suppliers of hosting services, IT and other office equipment, and other services including office cleaning and facilities, and professional services from our lawyers, accountants and other advisors.

DUE DILIGENCE PROCESSES /AREAS OF RISK AND MANAGEMENT

We have undertaken an analysis of the company’s internal policies to ensure that they uphold our desire to respect and protect human rights with regard to modern day slavery.  We are also carrying out annual due diligence on our suppliers to identify any which fall into a higher risk category. Categories and services which may be of a higher risk of modern slavery will be identified based on a calculated risk assessment taking in to account, governance structures, location, spend and product or services of the supplier. As a result of this assessment our action points may include, but are not limited to, updating our supplier terms and condition to include information on modern slavery and human trafficking.

SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS

FDB does not accept modern slavery and human trafficking and we have in place processes when working with suppliers to:
1. Conduct a risk assessment of a new supplier and its supply chains before agreeing to any engagement with that supplier, including considering its location, our spend and the product group and any risks raised of modern slavery or human trafficking; and 
2. Monitor supply chains and where appropriate audit suppliers once they have been engaged.

OUR COMMITMENT

FDB is committed to acting with empathy in our business relationships, ensuring that we are applying the necessary controls within our organisation to endeavour to minimise the risk of modern slavery and human rights violations across our business operations and supply chains.