Our Existing Framework
We appointed our first full time Group Compliance Officer in May 2019 to introduce a comprehensive compliance programme, addressing matters of global concern such as corruption, as well as Human Trafficking and Modern Slavery. This programme undertook a review and gap analysis across Hyve’s suite of compliance policies and procedures, ultimately resulting in the implementation of new, refreshed policies and re-invigorated training programmes.
Furthermore, as part of this compliance programme implementation, arrangements in relation to preventing Modern Slavery have been created, including a new Anti-Slavery and Human Trafficking policy which was approved by the Group’s Risk Committee on 11 September 2019.
A New Policy
In adopting a Group-wide Modern Slavery policy, we are demonstrating a global commitment to address Modern Slavery in our business.
It was recognised that the Modern-Day Slavery Statement is a “one-time” communication. By adopting a policy we are able to demonstrate a continuous and ongoing requirement to identify and act on Modern Slavery, which was not an item previously within the Hyve policy framework. The policy gives workers, contractors and other business partners guidance on Modern Slavery and clearly states the measures already taken and yet to be taken by Hyve to tackle Modern Slavery in its business and supply chains.
The new policy will be combined with the Group’s updated Whistleblowing Policy and newly implemented Whistleblowing reporting line, which will “go live” in early 2020.
We have also assessed our current risks in respect of Modern Slavery, based upon the findings of the Global Slavery Index report and in reference to the following criteria:
- the Group’s geographical footprint by event;
- geographical footprint by offices from which we operate; and
- event sector profile in each country.
There are arrangements in place for concerns in this regard to be raised, anonymously if needed, via our whistleblowing process.
One of the key components of the compliance programme is the delivery of a reliable and repeatable process by which due diligence is undertaken on our third parties. We have purchased new software to allow for such due diligence checks (including capturing adverse media reports for companies, globally, in relation to their practices and any reported prosecutions or sanctions). The software and process are due to be piloted from April 2020.