Sapient Limited

Modern Slavery Statement

Introduction

This statement outlines the actions taken by Sapient Limited (the “Company”) to prevent slavery and human trafficking within its business and supply chain. The Company is committed to improving its practices to combat slavery and human trafficking. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and constitutes the Company’s slavery and human trafficking statement for the financial year 1 January 2016 to 31 December 2016.

Organisational Structure and Business

The Company operates as a consulting and interactive services company, offering consulting services such as business and information technology strategy, business applications, business intelligence, industrial solutions, and outsourcing services. The Company’s ultimate parent company is Publicis Groupe S.A, a French incorporated listed entity (the “Groupe”).

Our Supply Chains

The Company’s supply chains include production companies, software developers, IT and other office equipment providers, professional services, office cleaning, and other office facilities services. The Company is based in the UK, as are the majority of its suppliers. The supply chain is considered low risk and non-complex in structure.

Our Policies on Slavery and Human Trafficking

Our position on slavery and human trafficking is clear. We have long-established policies, processes, and practices in place to prevent these issues within our business operations and supply chains. We continuously seek to enhance these processes and currently undertake the following measures:

It is now our policy to require our suppliers to adhere to our supplier code of conduct (the “Code”). Among other governance and compliance obligations referenced in the Act, the Code sets out the minimum behaviours, standards, and practices we expect from our suppliers. It prohibits forced labour, discrimination, and child labour, ensures supplier working conditions are safe, and that workers are treated with respect and dignity, with the aim of preventing slavery and human trafficking in our supply chains or business operations. The Code is published on our external website, and all new suppliers are required to read and acknowledge it as part of the onboarding process.
Our Purchase Order Terms and Conditions and Global Supplier Agreements require our suppliers and vendors to comply with all applicable laws and have recently been updated to include compliance with the Act and the Code.
We practice responsible procurement. Contracts signed with major suppliers, whether central or regional, are encouraged to mobilize in favour of human rights through our internal ‘CSR Procurement Charter’ and ‘CSR Procurement Questionnaire’, which are sent to all suppliers during the tendering process. Suppliers are also sent CSR Procurement guidelines, and their actions and commitment to CSR are tracked through our internal platform, EcoVadis. Only suppliers who have conducted the self-assessment may progress to the next step, which is the selection process. Our major suppliers are encouraged to join the EcoVadis platform, which, among other things, audits suppliers’ corporate social responsibility standards, including health and safety, environment, and ethics, so that we can measure and monitor their progress and achievements with our compliance policies.
We comply with all relevant UK employment laws and have internal policies in place to prevent slavery and human trafficking. These are included in the employee handbook, which is circulated to all employees and covers recruitment, health & safety, harassment, anti-bribery, equal opportunities, and diversity. Our employees have access to a confidential whistleblowing process for raising concerns, and we continue to increase awareness among employees through training on issues relating to slavery and human trafficking so that they may report any concerns as they arise. Since the Act came into force, we have drafted an Anti-Slavery & Human Trafficking policy, which has been included in the employee handbook, accessible to all employees and communicated to all new joiners during the induction process.
The Groupe has been a signatory of the Global Compact 10 Principles of the United Nations since 2003, which includes protecting universal human rights and the elimination of all forms of forced and compulsory labour and child labour. The Groupe is committed to ensuring these principles are observed, as highlighted in its code of conduct and a defined set of internal policies, procedures, and processes framework (known as JANUS). JANUS sets out the compliance and governance processes applicable to all its global subsidiaries, including the Company, to help prevent slavery and human trafficking and promote human rights. JANUS is available to all employees.

Risk Assessment and Due Diligence

With the introduction of the Act, we assessed our supply chain for potential areas of increased risk of slavery and human trafficking. As part of our initiative to identify and mitigate the risk of slavery and human trafficking in our supply chains, we conducted a review of our major suppliers and identified those in high-risk areas.

We ask our existing and new suppliers to complete a self-assessment questionnaire detailing any actions, procedures, policies, and practices carried out by their organisation to prevent slavery and human trafficking. Suppliers must agree to adhere to the Code, a copy of which is attached to the questionnaire, and they are also required to annually certify a declaration form confirming understanding and compliance with the Code and the Act.

High-risk suppliers receive a more detailed review of their questionnaires to identify areas of concern that may conflict with our Code or the Act, better understand the risk, provide feedback, and agree on steps to improve their processes. High-risk suppliers that receive special attention include companies that operate using temporary low-skilled workers, operate outside the UK or EEA, and/or manufacture or trade in raw materials outside the UK or EEA.

We will continually assess our compliance with the Act through annual audits carried out by our legal, procurement, and internal audit teams.

Further Steps

We will periodically review the effectiveness of our processes and systems, and any changes will be reflected in future annual statements.

This statement has been approved by the board of directors of the Company.

Signed
For and on behalf of Sapient Limited
Director
Date: 6/7/2017

Sapient Limited
Eden House
8 Spital Square
London E1 6DU
United Kingdom

TEL +44 (0) 207 786 4500
FAX +44 (0) 207 786 4600
sapient.com

VAT Registration Number: 718603436. Registered in England. Company Number: 3144067
Registered Office: Sapient Limited, Eden House, 8 Spital Square, London E1 6DU, United Kingdom