Modern Slavery Declaration
Declaration on Slavery and Human Trafficking for the Fiscal Year 2018
We have issued this statement in accordance with section 54 of the Modern Slavery Act 2015 (the “Act”) on behalf of ZPG Limited and its subsidiaries * (“we”, “us” or “our”). It describes the steps we have taken during the year to prevent modern slavery and human trafficking in our supply chains and in our operations in general.
Our structure, activities and supply chain
We own and operate some of the UK’s most trusted digital platforms including Zoopla, Uswitch, PrimeLocation, Money.co.uk, Bankrate, Property Software Group and Hometrack.
We create value by investing in the commercialization of our brands and by increasing our audience and by developing the best products and platforms to engage our consumers and partners.
Consumers increasingly use and rely on our platforms for real-time information on real estate and comparison markets. Likewise, real estate professionals and home service providers use our platforms to reach an audience ready to transact and market their products and services.
Our supply chains include the following:
- People: recruitment and training services.
- Marketing: media advertising and market research services.
- Professional services: advisory and consultancy services.
- Facilities: maintenance and cleaning services.
- Technology: external data centers, data providers, IT infrastructure, IT hardware providers, cybersecurity services, and software providers.
Our policies on slavery and human trafficking
We respect human rights and the integrity of individuals. We follow all relevant laws in the way we run our business.
We have a whistleblower policy in place that applies to all of our employees, officers, consultants, casual workers and agency workers. This “Speak Up” policy encourages all who work for us to report any professional misconduct or unlawful act, including suspicions of modern slavery and human trafficking, or omissions or similar issues by other employees. or former employees, contractors, suppliers, partners or advisers using a prescribed reporting procedure.
We engage an external and independent UK based third party to provide a reporting service allowing individuals to bring areas of concern to us in a secure and confidential manner. This facility includes access to a confidential 24/7 whistleblower hotline.
We are also committed to conducting our business in an ethical and legal manner, which includes ensuring, to the extent possible, that all third parties who act on our behalf share this commitment. The Company’s “Working with Third Parties” policy is in place to help identify and mitigate the risks associated with third parties who may provide services to us or on our behalf. This includes advice on performing appropriate due diligence with respect to existing or potential third parties on the basis of identifiable risks.
We have group-wide model clauses that are included in the appropriate contracts that allow contracting parties to formally recognize, commit to and comply with applicable law against slavery and human trafficking.
Due diligence and contracting process
We perform due diligence on our suppliers by requesting information from them (which includes information about the steps they are taking to ensure that there is no modern slavery or human trafficking in their business. or their supply chains). We keep our due diligence process under constant review, and it was last reviewed and updated in April 2019.
We consider supplier responses to our due diligence requests as part of our decision-making processes when it comes to bringing in new suppliers. We take appropriate action and, if necessary, delay or cancel the appointment of a new supplier unless the supplier’s systems and controls are satisfactory.
Assess and manage risks
Due to the nature of our business, our supply chains are limited and we only work with a small number of suppliers.
Nevertheless, we select some of our suppliers on the basis of ethical certifications (some of which – for example, Fairtrade certification – impose obligations on suppliers to eliminate modern slavery). These suppliers must prove their ethical certification before entering into contracts with them.
We also seek contractual assurances from suppliers regarding compliance with modern slavery and human trafficking, especially when these suppliers operate in supply chains that present higher risks of modern slavery. or human trafficking or we are one of them.
We continued to advise and guide the relevant sales teams directly responsible for concluding contracts with suppliers. We will introduce specific guidelines on modern slavery and human trafficking in our induction materials for newcomers.
This statement was approved by the Board of Directors of the Company on June 11, 2019.
Click here for ZPG Limited Modern Slavery Declaration 2017.