The U.K. Modern Slavery Act of 2015 (the "Act") requires commercial organizations that supply goods or services in the U.K. and which have a total annual turnover above £36m to publish a slavery and human trafficking statement each financial year. This statement should disclose the steps the organization has taken to ensure there is no slavery or human trafficking in its supply chains or its own business.
Gallup's effort is headed by the regulatory compliance officer (RCO) as a part of the overall Gallup Ethics and Compliance Program. The World Poll regional research directors work closely with the RCO as a part of the program. The CSR and Vendor Ethics policy is reported on and monitored by the Internal Audit Sub-Committee of Gallup's board of directors.
CSR and Vendor Ethics Policy
Gallup's CSR and Vendor Ethics program is shaped by legal requirements, Gallup's chosen ethics, market, industry and societal norms, and the commercial context in which Gallup operates. The team has a clear understanding of existing mandatory and voluntary CSR regimes.
Gallup's program design is responsive to mandatory regimes to ensure compliance with the law. The program adheres to other related corporate governance policies (for example, codes of conduct, Foreign Corrupt Practices Act policies and data security policies). Gallup implemented its program in late 2015 as a Voluntary CSR Vendor Ethics regime.
The RCO considers existing and current:
- governance policies, Gallup's chosen ethics and Gallup's goals
- budget, resources, management and accountability structures
- prevailing thoughts, opinions, activities and commitments of employees and other stakeholders
In 2016, Gallup assessed levels of risk with our vendors in Europe, Africa, Southeast Asia and Latin America.
We also took the following anti-slavery and anti-corruption steps:
- identified regions that are the most difficult for our vendors to operate within the bounds of Gallup's chosen ethics and within global anti-corruption laws
- completed RCO visits with vendors in high-risk regions to reinforce Gallup's commitment to supply chain transparency and ethics
- instituted a clause in all vendor contracts to certify that vendors are in compliance with Gallup's chosen ethics and global anti-corruption laws
Gallup is committed to this plan at every level. As with other corporate policies, this commitment demands:
- executive committee buy-in and communication to the whole World Poll and international survey research team
- realistic procedures that are tailored to achieve implementation of set goals
- effective, rolling communication with vendors, and addition of compliance and ethics into vendor training programs
- readiness to provide adequate responses to internal and external investigations and audits
- regular program review
In 2016, Gallup hosted regional meetings with all vendors. Gallup's RCO attended multiple days of these meetings and trained on Gallup's policies and the law governing anti-corruption and other international labor regulations, and informed them of Gallup's resources to assist them with compliance.
In addition, Gallup's RCO spent time with Gallup's board of directors to brief them on Gallup's efforts to prevent slavery and forced labor in its supply chains.
Gallup's RCO will conduct 2017 trainings in Southeast Asia, North Africa, Latin America and Europe.
As a member of Gallup's board, I have read and can attest that the above anti-slavery and anti-corruption disclosures are true and that Gallup's board is committed to ensuring a slavery-free supply chain.
/s/ Steven D. O'Brien