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 and his representatives as a part of the program. The CSR and Vendor Ethics policy is reported on and monitored by the Internal Audit Subcommittee 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 2020, Gallup assessed levels of risk with our vendors and suppliers in all regions in which 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 in, 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
- 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 2020, Gallup conducted regional meetings with all vendors. The Gallup RCO's representative attended these meetings in person with its vendors from the Latin America region, but because of the unprecedented COVID-19 pandemic, the other trainings occurred via live remote training for the Asia region, and a prerecorded video for all other regions, including Africa, Eastern and Western Europe, and Middle East and North Africa (MENA).The trainings included information and guidance 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. For the regions that the RCO's representative was unable to meet with in person or via live remote training, the RCO's representative spent time with the regional directors of those regions to stress the importance of communication and oversight of all vendors to ensure compliance with Gallup's ethics and the adherence to our anti-slavery and anti-corruption efforts. These regional directors in turn reviewed Gallup's policies and the law with the Gallup vendors in their regions on the RCO's behalf and provided a prerecorded training of the RCO's representative on the topic of anti-slavery and anti-corruption.
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