Modern Slavery Act transparency statement

Our commitment

dotdigital Group plc is a global organization in the provision of intuitive Software as a Service (SaaS) technology and tools for digital marketing professionals. It is the parent company of dotdigital and Fresh Relevance and employs approximately 470 people worldwide and has business operations in the United Kingdom, Poland, the Netherlands, the United States of America, Australia, South Africa, Singapore and Japan.

The dotdigital Group has a global annual turnover of £79m. You can find out more about the nature of our business on our website.
Slavery and Human Trafficking remain a hidden blight on our global society. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain.

The dotdigital Group is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

We are committed to acting ethically and with integrity in all our business relationships and taking reasonable steps to ensure slavery and human trafficking are not taking place in any business or organization that has any sort of a business relationship with our organization.

Due diligence processes for slavery and human trafficking

The dotdigital Group has zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors to comply with our values.

As part of our initiative to identify and mitigate risk, the dotdigital Group has in place systems to encourage the reporting of concerns and the protection of whistleblowers.

We expect our suppliers to have suitable anti-slavery and human trafficking policies and processes.

In order to implement our initiative to identify and mitigate risk, we review all suppliers before engaging with their services to identify any risks. We have adopted the Supplier Code of Conduct and are in the process of adopting a new supplier management system to continually monitor supplier adherence to our expectations.

Training

All employees receive an induction into the business where our policies, procedures and expectations are outlined. The management team are responsible for compliance within their respective departments and in their supplier relationships. As part of our process review, we have a training programme including specific sections on anti-slavery and human trafficking in place and all employees must complete this training on an annual basis.

Our effectiveness in combating slavery and human trafficking

The dotdigital Group has determined the following key performance indicators to measure effectiveness to ensure that slavery and human trafficking are not taking place in any part of our business or supply chains:

• A review of supply chain policies, codes of conduct and our working practices to show commitment.
• Ensuring we maintain a level of communication and personal contact with the next link in the supply chain to ensure their understanding of, and compliance with, our expectations.

Reporting suspicions of slavery

Employees can report any suspicions of slavery either through the dotdigital Group’s Public Interest Disclosure (Whistleblowing) policy, to the Compliance Officer or externally to the Modern Slavery Helpline. Details are set out below:
https://modernslaveryhelpline.org/
0800 0121 700

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement.

This statement was approved by the Board of Directors on 26 November 2024.

__________________________
Date: 26 November 2024
Name: Milan Patel
Position: Chief Executive Officer