MODERN SLAVERY & HUMAN TRAFFICKING STATEMENT
Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.
At ZULU SPORTS ANALYTICA, we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete
steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year 2020.
Our business and supply chains We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the
supplier’s reputation, respect for the law, compliance with health, safety and environmental standards, and references.
[We haven’t been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities.]
In the past year, we conducted a risk assessment of our supply chain by taking into account:
• The risk profile of individual countries based on the Global Slavery Index
• The business services rendered by the suppliers
• The presence of vulnerable demographic groups
• A news analysis and the insights of labour and human rights groups
Policies : ZULU SPORTS ANALYTICA operates the following policies for identifying and preventing slavery and human trafficking in our operations:
• Whistleblowing Policy – we encourage all employees, customers and suppliers to report any
suspicion of slavery or human trafficking without fear of retaliation. We provide a confidential
helpline to protect the identity of whistle-blowers.
• Code of Conduct – our code encourages employees to do the right thing by clearly stating the
actions and behaviour expected of them when representing the business. We strive to maintain
the highest standards of employee conduct and ethical behaviour when operating abroad and
managing our supply chain.
• Purchasing Data Code – we have updated our Purchasing Code and supplier contracts to make explicit reference to slavery and human trafficking.
Supplier due diligence
ZULU SPORTS ANALYTICA conducts due diligence on all new suppliers during on-boarding and on existing suppliers at
regular intervals. This includes:
• Assessing risks in the provision of particular services
• Auditing the suppliers, and their health and safety standards, labour relations and employee
• Requiring improvements to substandard employment practices
• Sanctioning suppliers that fail to improve their performance in line with our requirements
o We require all suppliers to attest that:
• They don’t use any form of forced, compulsory or slave labour
• Their employees work voluntarily and are entitled to leave work
• They provide each employee with an employment contract that contains a reasonable notice
period for terminating their employment
• They don’t require employees to post a deposit/bond and don’t withhold their salaries for any
• They don’t require employees to surrender their passports or work permits as a condition of
Awareness ZULU SPORTS ANALYTICA has raised awareness of modern slavery issues by putting up posters
across our facilities and sending an email that is focused specifically on modern slavery to all our staff,
• Our commitment in the fight against modern slavery
• Red flags for potential cases of slavery or human trafficking
• How employees should report suspicions of modern slavery
Training In addition to the awareness programme, ZULU SPORTS ANALYTICA has rolled out a fresh e-learning
course to all employees and supplier contacts, which covers:
• Various forms of modern slavery in which people can be held and exploited
• The size of the problem and the risk to our organisation
• How employees can identify the signs of slavery and human trafficking, including unrealistically
• How employees should respond if they suspect slavery or human trafficking
• How suppliers can escalate potential slavery or human trafficking issues to the relevant people
within their own organisation
• What external help is available for the victims of slavery
• What terms and guidance should be provided to suppliers in relation to slavery policies and
• What steps ABC plc will take if a supplier fails to implement anti-slavery policies or controls
• An attestation from employees that they will abide by ABC plc’s anti-slavery policy
Measuring how we’re performing
ZULU SPORTS ANALYTICA has defined a set of key performance indicators and controls to combat modern slavery
and human trafficking in our organisation and supply chain. These include:
• How many employees have completed mandatory training?
• How many suppliers have filled out our ethics questionnaire?
• How many suppliers have rolled out an awareness and training programme that is equivalent to
• How many reports have been made by our employees that indicate their awareness of and
sensitivity to ethical issues?
What are the findings of our cross-functional Human Rights team, which reviews how we are
addressing modern slavery and human trafficking?
This statement has been approved by the board of ZULU SPORTS ANALYTICA at the board meeting on March 20th 2020