MODERN SLAVERY & ETHICAL TREATMENT STATEMENT, 2021
2021 Standard Language
We do not tolerate any form of modern slavery or human trafficking in any part of our business. This commitment is outlined in our Human Rights Policy, which reflects international standards and principles including the International Bill of Human Rights, the UN’s Guiding Principles on Business and Human Rights, the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work and the Children’s Rights and Business Principles.
Our policies are developed within relevant departments following a process of stakeholder consultation, cross-departmental information sharing and senior management review and approval. Notary.Online provides a clear policy framework, which is communicated to our operating brands and suppliers, newsletters, eLearning, onsite training and emails.
We want to ensure that risks and opportunities are managed consistently across Notary.Online and that our policies are implemented across our brands and locations and with our suppliers. Notary.Online provides ongoing support to encourage and facilitate implementation of the policies by the operating brands. In addition, our internal sustainability advisors are working with our operating brands to review implementation of our standards and to identify and address areas for improvement.
2019 & 2020 Additional Language
Everyone, everywhere, no matter who they are or what they do, deserves to be adequately compensated for their work, period.
“A living wage” is what the world overwhelmingly calls it! But we’re calling it “Ethical Treatment”.
Ethical Treatment is taking a front and center position in our social responsibility efforts.
We’ve notified our suppliers, in the U.S. for instance, that they must pay their employees a minimum of $16.00 per hour if free health insurance or health care is provided, and $21.00 per hour if they do not provide free health insurance or healthcare. This applies to their employees, and personnel that are performing services for them pursuant to a contract such as through a temp agency, etc. This policy is unambiguous: it applies to everyone – any employee, no matter their charge!
The amount of remuneration will obviously differ Country to Country, and we are still developing a frame-work outside of the U.S.
What does that mean?
It means that when customers come to us, right after we welcome them and seek to understand their needs, we will ask about their treatment of their employees. If they do not treat their employees ethically, we will decline their business.
2017 - 2018 UPDATES
In early 2018 we revised our procurement policy to embed more specific criteria in the supplier selection process and provide guidance on assessing supplier compliance. We also included a new procedure for the completion and evaluation of a supplier questionnaire to strengthen our due diligence process for supplier selection.
At the end of 2017, we developed new sustainability questionnaires to strengthen our due diligence process for supplier selection. The first, a pre-selection questionnaire, is for use with all potential new suppliers. It assesses compliance with our core standards for legal compliance, labor and human rights practices, environment and supply chain management.
A second, a more detailed information request, will be used with selected suppliers to monitor standards in our supply chain and work with suppliers to address gaps and risk areas.
Due Diligence in Our Business and Our Supply Chain
We conducted an internal risk assessment by evaluating country risk in relation to office location and size, type of labor and business operations. Given the nature of our business in these countries and that most of our people are direct employees, we ascertained that the risk of trafficking or slavery amongst this category is very low.
Our main categories of spend include IT, telecommunications, professional services and facilities and those used in client work, such as servers, market research and other marketing services.
Notary.Online manages the appointment of “approved suppliers”, where contracts are entered into at the Notary.Online parent level. An “approved supplier” is defined as one that has been appointed following evaluation against assessment criteria, including risk, operational, commercial and sustainability considerations.
Each FA operating brand is required to use Notary.Online’s “approved suppliers” for commonly purchased goods and services, whenever possible. In addition, each operating brand is expected to maintain a list of locally approved suppliers based upon the formal selection process outlined in FA’s procurement policy. It is the responsibility of our operating brands to select, monitor and manage any suppliers that they use if they are not listed on Notary.Online’s central “approved supplier” list. Our sustainability team is working with our operating brands to ensure they take a consistent approach to implementing our responsible sourcing standards.
As part of our procurement policy, Notary.Online expects all of our suppliers to abide by the same principles outlined in our Codes of Conduct. Our suppliers must either agree to adhere to our Codes of Business Conduct or confirm their adherence to their own Codes of Business Conduct that comprises the same principles. We also include a “right to audit” clause in our purchase orders and contracts.
We have assessed the risk of modern slavery amongst the Notary.Online parent company approved supplier partners, across nine categories of spend. To ascertain the risk of modern slavery among these supplier partners, we evaluated their category risk in relation to category spend.
Almost 90% of our spend with approved supplier partners is in low-risk categories such as professional services. We identified facilities and promotional goods as high-risk categories. For the country risk evaluation, we referred to Maplecroft’s Global Modern Slavery Risk Index. 97% of our spend with approved supplier partners is in countries deemed low-risk according to the Index. For promotional goods, which was found to be high risk in country and category, we not only assessed our approved supplier partners but also additional suppliers where the relationship is managed by our operating brands. In 2018, 2019, and 2020, we revaluated our risk assessment following feedback from our operating brands and moved a category of operations from low to medium risk.
Notary.Online has a third-party-managed “Right to Speak” helpline that is in place throughout the business and is overseen by Notary.Online’s legal and internal audit departments. All employees (direct and indirect) have access to this helpline through which they can report any concerns or suspected cases of misconduct, including suspicions of forced labor or trafficking activities.
This is publicized through induction packs, electronic mail, the Notary.Online Policy Book and our ethics training. Each operating brand is responsible for ensuring that all employees, contractors, and suppliers are informed about the helpline.