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 its 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 and his representative 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 2021, Gallup assessed levels of risk with our vendors and suppliers in all regions we operate.
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 trainings with all vendors, including those in high-risk regions to reinforce Gallup's commitment to supply chain transparency and ethics
- spoke directly with our Regional Directors and the vendors in the regions about the specific challenges they faced
- maintained a clause in all vendor contracts to certify that vendors are in compliance with Gallup's chosen ethics, global anti-corruption laws, and global labor regulations
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 2021, Gallup conducted regional ethics training meetings with all of it World Poll vendors. Gallup's RCO representative conducted these meetings via live remote training through video conferencing with the following regions: Africa, Latin America, Eastern Europe, Western Europe, Middle East and North Africa (MENA), and Asia. The trainings included information and guidance on Gallup's policies and the laws governing anti-corruption and other international labor regulations, including the strict prohibition of any forced or compulsory labor, as well as informing the vendors of Gallup's resources to assist them with compliance. The RCO's representative spent time with the regional directors of those regions and their respective World Poll vendors allowing them to ask questions or express challenges and concerns in their regions. The RCO's representative stressed the importance of communication and oversight of all of the vendors' supply chains, both vertically and horizontally, to ensure compliance with Gallup's ethics and the adherence to our anti-slavery and anti-corruption efforts.
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.
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