Oath (UK) Limited (“Oath”) Modern Slavery Act Statement for the Financial Year ending 31 December 2016

1: Opening statement

Oath is a media technology company operating a variety of content sites and platforms that connect publishers with advertisers using its programmatic advertising technology. Oath is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain. The digital world promises a better, more connected life, and we are delivering it. We make it possible for people to stay in touch and businesses to connect with their customers. We work better because our team is comprised of people from diverse backgrounds and experiences. We work with suppliers that follow the highest ethical standards.

2: Structure of the organisation

 Oath is a UK-subsidiary of Oath Inc.  Oath Inc. was acquired by Verizon Communications Inc in June 2015.  Oath Inc. and its UK subsidiaries are operating companies in the Verizon Communications Inc. group of companies (“Verizon Group”).  Oath (UK) Limited was formerly known as AOL (UK) Limited and Oath Inc. was formerly known as AOL Inc.

Oath is a leading company in the media technology sector. Oath employs approximately 488 people in the UK.  While this statement is submitted on behalf of Oath, it also further describes actions taken by the Verizon Group on behalf of all of its subsidiaries, including its UK subsidiaries,  in respect of supply chain due diligence.
To find out more about the nature of our business, please click http://www.corp.aol.com .

In order to provide our services, we contract with a broad range of suppliers including technology solutions providers, professional services organisations, outsourcing specialists, network engineering vendors and facilities management vendors.  Contracting with suppliers, and diligence activities with respect to our supply chains, are conducted primarily by functions at the Oath Inc. corporate level.

3: Policies

As part of our commitment to combating modern slavery, we have implemented and enforced the following policies:

The Oath Standards of Business Conduct define our ethical business practices.

Our Supplier Code of Conduct defines the ethical business practices that our suppliers must adhere to.  Oath’s Supplier Code of Conduct is attached to this statement.

Our personal contact with and due diligence review of suppliers is the primary mechanism we use to ensure suppliers promote ethical conduct in the workplace, safe working conditions and the treatment of workers with respect and dignity.  It is our general practice to review the vendor’s business profile, and examine various risk factors to determine whether the vendor is at risk for non-compliance with our policies and expectations. 
Under the Supplier Code, Suppliers are required, and the public is encouraged, to report violations of the standards in our Supplier Code.  Under the Supplier Code, Suppliers are further bound to prevent any retaliation against whistle-blowers.
4: Due diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted the due diligence procedures described below.

Our procedures and policies are designed to:
  • establish and assess areas of potential risk in our business and supply chains
  • monitor potential risk areas in our business and supply chains
  • reduce the risk of slavery and human trafficking occurring in our business and supply chains
  • provide adequate protection for whistle-blowers

Oath is engaged in an ongoing assessment of the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain by reviewing with our supervisory procurement personnel areas of the Oath supply chain that are (i) international (ii) high-turnover in nature, and (iii) where Oath had the greatest leverage to influence the actions of such supply chain. We sent out surveys to certain suppliers that, based on our assessment, most reflected the above three factors, in particular with respect to call-centres.
In addition, we have updated our audit protocol with respect to such activities to add greater focus on modern slavery matters.

Verizon Communications Inc. is a member of the Joint Audit Cooperation (JAC) program, an association of thirteen large telecommunications operators who share resources to develop and enforce standards and best practices within the information communication technology supply chain.  The audit activities cooperatively assess and verify compliance with recognized labour, social and environmental standards, including with respect to forced labour, underage labour, and working hours.  Members of JAC fund shared assessments and audits of their common suppliers; audits are conducted by independent auditors.  JAC reduces redundancy and increases efficiency in supply-chain audit approaches by auditing shared suppliers once per cycle, using uniform protocols and methods.  

5: Risk and compliance

In general, we respond to suspected or actual violations of our Supplier Code in a flexible manner appropriate for the nature of the violation.  While egregious violations can result in Oath exiting a supplier relationship, we intend that most noncompliance will be addressed by investigation and where appropriate the establishment of a corrective action plan. 

6: Training

Verizon Group developed training in 2016 to assist its procurement employees in recognising the risks of modern slavery and human trafficking in our business and supply chains, and to assist in the risk assessment described above.  The training also focuses on the sourcing and procurement team’s role in interacting with Suppliers to improve our due diligence.  The training is currently delivered in live sessions by members of our Legal team.  In 2016, most of the sourcing personnel at the supervisory level of Oath have been given such live training.  

7: Further actions and sign-off

Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to expand our survey program to include  international, high-turnover supply chains to tackle slavery and human trafficking.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Oath’s slavery and human trafficking statement for the financial year commencing 1 January 2016 and ending 31 December 2016.
Stuart Flint
Managing Director
Oath (UK) Limited
July 1, 2017
Encl.: Oath’s Supplier Code of Conduct

Oath Supplier Code of Conduct
Oath holds itself and its suppliers to the highest ethical and business practices. Oath employees apply our Standard of Business Conduct (“SBC”) to our business. This Supplier Code of Conduct (“Supplier Code”) provides our expectations for suppliers and contractors working on your behalf who provide goods and services to Oath. The Supplier Code supplements, but does not supersede, contract terms between you and Oath.
We expect you to fully comply with laws, rules and regulations that apply where you operate and/or provide goods and/or services to Oath.  In some cases, the Supplier Code includes higher standards than the law prescribes. In those cases, we expect that you will adhere to the higher standards.  We also expect you to:
  1. Engage with ethics and integrity.  Oath expects its suppliers to engage in all activities with the highest degree of ethics.  Suppliers may not engage in illegal or inappropriate activities in conducting business for or with Oath.  As examples, Oath strictly prohibits corruption, extortion, embezzlement or bribery, and expects suppliers to prepare accurate, truthful and complete records.  Compliance with laws is not enough; we expect that you will avoid any situation that has any appearance of impropriety.
  2. Comply with laws related to bribery and anticorruption: Suppliers must comply with all laws and regulations related to bribery and corruption.  This includes, but is not limited to, the United States’s Foreign Corrupt Practices Act, the UK Bribery Act, France’s Law on Transparency, the Fight against Corruption and Modernization of Economic Life, and similar local laws. We also expect that you will not engage in any conduct that would result in harm to your or our reputation, whether or not it is illegal.  
  3. Compete fairly.  Suppliers must apply fair business standards in all Oath-related activities, including advertising, sales, and competition.  Only reference Oath or any of its products, services, employees, or affiliates in advertising, marketing or promotional activities if you have received prior written permission from Oath’s Corporate Communications [insert hyperlink] team. In each case, we expect that you will accurately and honestly represent Oath.
  4. Help us maintain a professional workplace.  We at Oath treat each other fairly and with respect and dignity. We give every employee an equal opportunity to succeed.  We create a business atmosphere that encourages and celebrates diversity. Oath business operations do not include child or forced labor, slavery, or human trafficking.  We do not tolerate discrimination based on any characteristic protected by law and do not tolerate any type of harassment.  Oath supports employee rights to freedom of association and to engage in concerted activity protected by law without fear of retaliation.   Our suppliers should apply all of these same standards.  
  5. Help us maintain a safe and healthy workplace.  Work areas should be conducive to healthy working and free from unsafe conditions.  Conflict should be resolved in a respectful and productive manner without threats, bullying, violence, or hostility.  Oath is a drug-free workplace and does not permit illegal drugs or controlled substances in our workplace, even where local law permits.  Do not abuse alcohol or prescription drugs while working or attending business functions on Oath’s behalf.
  6. Use and protect our resources responsibly.  Never permit unauthorized access to our space or systems.  Handle our company property - including assets and data - responsibly, honestly, and in accordance with applicable policies. Protect our intellectual property.  Respect the intellectual property of others when working on our behalf. Promptly inform us if you are aware of any violations of these conditions. 
  7. Respect our gifts and entertainment policy.  In addition to our anti-bribery requirements, we do not exchange cash or cash equivalents, such as gifts cards, with suppliers or other business partners.  Gifts and entertainment offered should be reasonable and have a legitimate business purpose.  They may not be offered in an effort to improperly influence a business decision or business relationship.  Gifts should be nominal courtesies.  If they could even appear to be a bribe or improper payment, do not offer or receive them.  Entertainment should not embarrass your company or ours, and should not occur in a way that could harm our companies’ reputations.  It is never acceptable for an Oath employee to solicit gifts, gratuities or entertainment, and gifts or special favors are not conditions of doing business with Oath.  Report any attempted bribery or inappropriate gifts or entertainment to our ethics helpline as note below.  
  8. Report possible violations.  Supplier employees should have the ability to report ethical concerns or violations of this Supplier Code or of Oath’s Standard of Business Conduct through an anonymous helpline to the extent permitted by law.  Suppliers who operate a hotline that allows employees to report violations or integrity issues can direct its employees to that hotline.  You may provide any staff engaged on Oath matters with the following Oath  Helpline information.  
Email: ECO@oath.com
Phone: 833-ASK-Oath
Online Webform: https://iwf.tnwgrc.com/sbcteamaol