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Working with integrity is one of our core values and central to The Experian Way of working.
Our Global Code of Conduct, available in several languages, sets out clear guidance to help everyone at Experian make the right decisions. It is supported by detailed policies on specific topics such as anti-corruption, gifts and hospitality, fraud management, complaint management, fair treatment of vulnerable consumers, product development and marketing, whistleblowing and tax.
We take a zero-tolerance approach to bribery or corruption in our business and our supply chain. Our Global Anti-corruption Framework prohibits facilitation payments, kickbacks, or any form of bribery or corruption.
The accompanying 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.
Effective assessment and mitigation of corruption risks are a critical component of our Compliance Management Programme for the business, and we conduct periodic assessments check for corruption risks. 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.
All employees (including part-time employees and contractors) complete mandatory training on our Code of Conduct and on anti-bribery and corruption when they first join Experian. Thereafter, they must complete refresher training every one to two years 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, and we encourage people to report any suspected policy breach or unethical activity without fear of reprisals. We ask employees to start by talking to their manager if they have concerns. Employees and third parties can also report any concerns, anonymously if they choose, through our 24-hour Confidential Helpline.
We take any allegations of ethical breaches very seriously. All reported concerns are investigated by relevant functions, such as Human Resources, Global Security Office or Global Fraud Investigations, to identify root causes and take appropriate corrective action. In 2020/21, 37 concerns were reported. The majority of these, 78%, concerned human resources related matters.
We are committed to respecting human rights and upholding the United Nations Universal Declaration of Human Rights (UDHR) and the UN Guiding Principles on Business and Human Rights (UNGP) in our business and supply chain. Everyone at Experian completes training on our Global Code of Conduct, which sets out clear standards to avoid any infringement of human rights.
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 they really need to live on.
In 2020/21, we have strengthened our focus on DEI globally and will publish our first Global DEI Report to enhance disclosure on this important topic. We have signed up to the UN Women’s Empowerment Principles, and our North American business received a perfect score from the Human Rights Campaign Foundation’s 2021 Corporate Equality Index on policies and practices for LGBTQ+ employees.
Our Supply Chain Principles set 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.
Supplier risk assessments and in-depth training help procurement teams identify risks of modern slavery in our supply chain, and take action if they have any concerns. Our Slavery and Human Trafficking Statement provides further information on our commitment, policies and actions to tackle modern slavery risks in our business and supply chain.
Experian is a founding member of the Slave-Free Alliance, which brings together businesses working towards a slave-free supply chain. Following a comprehensive assessment of our approach by the Slave-Free Alliance, we are completing a three-year improvement plan to improve our processes for identifying and preventing modern slavery risks in our supply chain. A quarterly steering group, headed by our Group Chief Procurement Officer and Head of Strategic Pricing, manages implementation of the plan. We have also invited members of the Slave-Free Alliance and our charity partner Hope for Justice to provide expert guidance. First steps in 2020/21 included assigning responsibility for mitigating risks and implementing improvements to the owners of relevant areas of the business.
We are using our data and analytics to support wider efforts to tackle modern slavery, and contribute to the United Nations’ Sustainable Development Goal to eradicate forced labour. Our DataLabs are collaborating with the United Nations University Centre for Policy Research and the University of Nottingham’s Rights Lab to develop an ‘analytical sandbox’ that will use a combination of datasets to help pinpoint locations that may be vulnerable to modern slavery risks. We are also working with Hope for Justice to support survivors of modern slavery.
Our Supply Chain Principles Code of Business Conduct represent 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.
We integrate risk management and compliance in our supplier selection process, alongside commercial considerations. We use our third-party risk management framework to conduct due diligence on suppliers and third parties before we work with them, and assess and monitor risks throughout our working relationship. Our Three Lines of Defence controls support compliance.
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).
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. Periodic 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.
In 2020/21, we have strengthened our processes for ongoing monitoring of higher-risk suppliers and third parties to include periodic sampling and testing of controls to ensure our standards are upheld. If we identify any gaps in controls, we log these in our centralised global governance, risk and compliance system, and track issues through to resolution. We will not work with – and routinely reject – third parties that do not uphold our standards on critical issues, such as data security.
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 support women and minority-owned suppliers as a member of the National Minority Supplier Development Council and the Women’s Business Enterprise National Council. Diverse suppliers account for around 6% of our US base.
To support our climate strategy, we are working with our most carbon-intensive suppliers to request data to help us get a better understanding of our Scope 3 carbon footprint.
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