The Global Code of Conduct is supported by detailed policies on specific topics such as anti-corruption, conflicts of interest, gifts and hospitality, fraud management, complaint management, fair treatment of vulnerable consumers, product development and marketing, whistleblowing and tax.
We are committed to creating and maintaining a robust, effective and appropriate control environment to recognise where opportunities for financial crime exist and mitigate the associated risk. We establish and maintain processes and procedures to monitor, detect and prevent acts of financial crime against Experian by third parties or employees, or through the unlawful use of or access to its products, services or data. If any financial crime is detected that has been committed by Experian employees, we will take appropriate disciplinary and legal action against the individual or individuals involved.
Our commitment to doing business responsibly includes our approach to tax. For several years, we have published our Tax Policy, which explains how we approach our tax affairs. As part of our commitment to increasing transparency, we have this year gone a step further and published a Tax Report, which explains our approach to tax governance and how we deal with our tax affairs, and provides more information on our tax contribution.
Anti-bribery and corruption
Our zero-tolerance approach to bribery and corruption is set out in our Code of Conduct and Global Anti-corruption Framework. We prohibit anyone acting on behalf of Experian from offering and/or accepting a bribe, or making a facilitation payment to officials, in connection with our business. This includes employees, third parties and suppliers.
Experian’s Global Gifts and Hospitality Policy sets out strict ethical standards relating to gifts, entertainment, hospitality, sponsorship, travel expenses and donations. We also have controls to ensure we conduct any sponsorships, charitable contributions, lobbying or political donations ethically and in compliance with all relevant laws.
Our suppliers are contractually obliged to ensure their employees, agents and subcontractors refrain from paying or receiving improper bribes, facilitation payments, gratuities or kickbacks. If we identify any suppliers as high risk for bribery or corruption, we refer them to the Compliance team for further due diligence, including an assessment of corruption, regulatory and reputational risks.
We conduct periodic assessments to check for and mitigate corruption risks as part of our Compliance Management Programme for the business. We also follow rigorous due diligence procedures to identify any risk of improper payments during mergers and acquisitions, or when we enter into joint ventures.
Our Finance and Global Sourcing teams have training and controls to detect and stop improper payments, with support from our Global Internal Audit team. If we identify any concerns, we promptly investigate them and take appropriate action.
Training and compliance
We strive to create a culture of integrity which empowers our people to make the right choices. Our Code of Conduct makes clear that everyone at Experian is accountable for managing operational risk across our business effectively to safeguard our future.
All employees (including part-time employees and contractors) complete mandatory training on our Code of Conduct when they first join Experian, and regular refresher training thereafter. They are required to acknowledge their understanding and confirm their commitment to the Code of Conduct every year, and we make sure that they do so through our performance review process. We also expect managers to be positive role models for ethical behaviour.
Any breaches of our Code of Conduct or associated policies could undermine our reputation and stakeholder trust. Our Three Lines of Defence risk management model reinforces our culture of compliance. We encourage people to report any suspected policy breach or unethical activity without fear of reprisals – and anyone who knows about a potential violation, and does not report it, could be subject to disciplinary action.
We ask employees to start by talking to their manager if they have concerns. They can also report any concerns, anonymously if they choose, through our 24-hour Confidential Helpline. The Helpline is open to both employees and third parties, and provides support in local languages.
We take any allegations of ethical breaches very seriously. All reported concerns are investigated promptly by relevant functions, such as Human Resources, Global Security Office or Global Fraud Investigations, to identify root causes and take appropriate corrective action. This year, 47 concerns were reported. The majority of these (77%) concerned human resources-related matters.
Respecting human rights
We are committed to respecting and promoting human rights, including upholding the United Nations Universal Declaration of Human Rights (UDHR), the United Nations Guiding Principles on Business and Human Rights (UNGP) and the International Labour Organization (ILO) Standards. This is reflected in our Code of Conduct and associated compliance policies – which everyone at Experian must confirm their commitment to every year. These policies make clear that we do not tolerate any infringement of human rights in our business or our supply chain.
This year, we conducted an analysis, based on best practice, to identify salient human rights for Experian. We have published a statement on salient human rights that sets out our approach to each of these: healthy and safe working conditions; workplace security; freedom of association; diversity, equity and inclusion; modern slavery and forced labour; access to grievance mechanisms; data protection and privacy; environment and carbon emissions. We recognise that other human rights issues may become relevant to Experian in the future and will review our salient issues on a regular basis.
We are committed to treating all our people fairly and with respect. Experian is an accredited Living Wage employer in the UK, going beyond the legal minimum wage to pay employees the amount the Living Wage Foundation has calculated to support a reasonable living. As set out in our updated Code of Conduct, we support our employees’ right to affiliate or not affiliate with legally sanctioned organisations or associations without unlawful interference.
Diversity, equity and inclusion (DEI) remains a key focus within our business (see page 56) and our Global DEI Report and beyond. We are a signatory to the UN Women’s Empowerment Principles. Experian North America was again listed as one of the best places to work for LGBTQ+ employees, with a perfect score in the Human Rights Campaign Foundation’s 2022 Corporate Equality Index. Our commitment to DEI is also fundamental to our purpose of creating a better tomorrow by making positive change in the world and actively supporting efforts to close the financial wealth gap of underserved communities (see page 56).
Our Supplier Code of Conduct sets out clear standards on human rights, and we include clauses in our contracts that oblige suppliers to protect workers’ rights and freedoms. We monitor compliance through our third-party risk management framework. We also expect suppliers to set similar requirements for their own suppliers and subcontractors to extend high standards throughout the supply chain.
Tackling modern slavery
We recognise that modern slavery can occur in any sector, anywhere in the world. We are committed to doing all that we can to eliminate the practice.
Experian is a founding member of the Slave-Free Alliance, which brings together businesses working towards a slave-free world. Following a comprehensive assessment of our approach by the Slave-Free Alliance, we are in the final year of a three-year improvement plan to develop our processes for identifying and preventing modern slavery risks in our supply chain. A quarterly steering group, headed by our Group Chief Procurement Officer, manages implementation of the plan.
Together with the Slave-Free Alliance, we ran an event for suppliers this year to increase awareness of modern slavery in the supply chain. We undertake an annual assessment of high-risk suppliers to ensure that they have policies and procedures in place to minimise the risk of modern slavery. Our Modern Slavery Statement provides further information on our commitment, policies and actions to tackle modern slavery risks in our business and supply chain.
We are using our data and analytics to support wider efforts to tackle modern slavery and contribute to the United Nations Sustainable Development Goal 8.7 to eradicate forced labour. Working in collaboration with the United Nations University Centre for Policy Research and the University of Nottingham’s Rights Lab, our DataLabs have developed a predictive model that draws on a combination of datasets to help pinpoint locations that may be vulnerable to modern slavery risks. We are now exploring potential applications for this tool by building relationships with private and government organisations.
We also continued our work with Hope for Justice to support survivors of modern slavery through advocacy and advice services, including helping them prove their identity, access credit reports and resolve fraudulent debts racked up in their name. This year, our partnership with Hope for Justice supported 418 survivors and engaged over 12,000 individuals through community engagement, outreach and training to help prevent exploitation and modern slavery.
Partnering with suppliers
Our Supplier Code of Conduct represents the minimum ethical, labour, human rights and environmental standards that all Experian suppliers must meet. As part of their contracts with us, all suppliers must confirm that they accept our standards or have their own equivalent standards in place.
ESG criteria are integrated in our supplier selection process alongside commercial considerations. Through our due diligence process, we ensure that selection is dependent on satisfactory governance of areas such as bribery, corruption and modern slavery. We have also strengthened our supplier selection process by requesting details of key suppliers’ carbon reduction plans as part of our request for proposals to support our Scope 3 emissions reduction target (see page 67).
We conduct a risk assessment of all the third parties we work with, including suppliers and indirect clients. Overseen by our Third Party Risk Management team, we assess risks related to data security and privacy, business continuity, compliance and reputation (including bribery, corruption and modern slavery). We will not work with – and routinely reject – third parties that do not uphold our standards on critical issues, such as data security.
Of the thousands of third parties we work with, most fall into the minor or moderate risk category in our initial risk assessment. Those we consider higher risk – based on factors such as the type of product or service they provide and the type of data they have access to – are subject to more in-depth assessments, oversight and controls.
As our First Line of Defence, the business function that owns the relationship with the third party is responsible for identifying, tracking and resolving any issues. We test our controls periodically, logging and resolving any issues identified through our centralised global governance, risk and compliance system. Reports on key suppliers, drawn from news sources around the world, help us monitor risks in our supply chain by alerting procurement teams and supplier relationship managers to any issues.
We are committed to supporting diverse suppliers through our strategic sourcing process that is designed to offer a level playing field for all third parties. In the USA, we are members of the National Minority Supplier Development Council, National LGBT Chamber of Commerce, Disability:IN and the Women’s Business Enterprise National Council. These organisations have supported our year-on-year growth of registered diverse and small business supplier relationships. We also plan to complete an analysis of the diversity of our suppliers in our UK business in the coming year.