For the Financial Year ending December 31, 2018
Index Exchange Limited, together with its parent company, Index Exchange Inc. (collectively, “Index Exchange”) has a zero-tolerance approach to human slavery and endeavors to understand all potential modern slavery risks related to its business. This statement is made in accordance with the United Kingdom’s Modern Slavery Act, 2015 and sets out the steps being taken by Index Exchange to ensure that there is no slavery or human trafficking in its business or its supply chains. This statement relates to actions and activities during the financial year January 1, 2019, to December 31, 2019.
II. Organizational structure and supply chains
This statement covers the activities of Index Exchange. Index Exchange is an online media and technology company engaged in, among other things, connecting sellers of online media inventory to a large selection of prospective purchasers across all verticals, and providing the technology needed to track, analyze, and optimize the value and utilization of such online media inventory. Index Exchange has offices in seven countries: Canada, the United States of America, the United Kingdom, France, Australia, Germany and Italy. Index Exchange has contracts in place with both sellers and purchasers of online media inventory as well as with the entities required to support it’s business (i.e. office technology providers, landlords, etc.).
III. Policies on Modern Slavery
Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains.
IV. Risk Assessment
Given the technological focus of Index Exchange’s business, its supply chains are principally for: (i) the provision of technology to its clients; and (ii) the procurement of: (A) office and IT equipment to support its office facilities; and (B) professional services from legal, accounting and consulting professionals to support its ongoing business. These supply chains are short and typically dependent on highly skilled, educated workers. As a result, Index Exchange assesses the risk of modern slavery or human trafficking in our business and our supply chains to be very low. Nonetheless, we are devoted to ensuring our business reflects our commitment to high integrity and legally compliant practices. With our UK operation, the key areas that could be affected by slavery and human trafficking are our employees, sub-contractors and suppliers. We mitigate risks in each of these areas in the following way:
a. We verify that all employees have the right to work in the UK upon commencement of their employment.
b. We make all employees aware of the terms and conditions of their employment through their contracts of employment and Index Exchange’s corporate policies as the same may be amended from time to time.
c. All employees are paid into a bank or building society account in their name.
a. We require sub-contractors to ensure that their employees are eligible to work in the UK.
b. We verify and communicate Index Exchange’s corporate policies and positions to our sub-contractors and require that they adopt and/or respect the same high standards as applicable.
a. We conduct due diligence on our suppliers and expect them to respect and adopt the same standards as Index Exchange regarding modern slavery and human trafficking as applicable.
Index Exchange is committed to fostering a transparent and responsible environment that reflects our commitment to high integrity practices including ensuring there is no modern slavery or human trafficking occurring in our business or in our supply chains. We encourage employees to report any concerns or wrongdoing without fear of penalty or persecution.
VI. Training & Awareness
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, Index Exchange will post its Anti-Slavery Policy on its intranet. In 2019, we also plan to conduct training on a revised Employee Code of Conduct; in this context, we will also provide training on our Anti-Slavery Policy which will help employees flag risks or indicators related to modern slavery and human trafficking.
This statement will be reviewed and updated where required on an annual basis. Responsibility for compliance lies with the management team. This statement is made pursuant to section 54(1) of the Modern Slavery Act, 2015 and constitutes Index Exchange Limited’s slavery and human trafficking statement for the financial year ending December 31, 2019.
Signed on behalf of Index Exchange Limited.
Executive Vice President, International