Anti-Modern Slavery Statement
For the Financial Year ending December 31, 2023
Effective Date: June 30, 2024
Introduction
Index Exchange Limited and Index Australia Pty Ltd., together with its parent company, Index Exchange Inc. (collectively, “Index Exchange”) have a zero-tolerance approach to all forms of servitude, forced and compulsory labour, and human trafficking, or any form of exploitation that deprives a person’s liberty by another in order to exploit them for personal or commercial gain (together “Modern Slavery”).
This Modern Slavery Act Statement (this “Statement”) is made in accordance with the United Kingdom’s Modern Slavery Act, 2015 and Australia’s Modern Slavery Act, 2018, and outlines the steps being taken by Index Exchange to ensure that there is no human trafficking or Modern Slavery in its business or its supply chains. This Statement relates to actions and activities during the financial year January 1, 2023, to December 31, 2023.
Commitment to Anti-Modern Slavery
This Statement reflects our commitment to: (i) acting ethically and with integrity in all our business relationships; and (ii) implementing and enforcing effective systems and controls to preclude Modern Slavery from taking place anywhere in our business or in our supply chains.
Index Exchange’s Employee Code of Conduct sets expectations and responsibilities for all employees to maintain ethical behaviour in all business dealings.
Organisational Structure and Supply Chains
Index Exchange is an online media and technology company engaged in, among other things, connecting sellers of online media inventory to a large selection of prospective purchasers across all verticals, and providing the technology needed to track, analyse, and optimise the value and utilisation of such online media inventory. Index Exchange has offices in eleven countries: Canada, the United States of America, the United Kingdom, France, Australia, Germany, Italy, Singapore, Spain, Japan, and India. Index Exchange has contracts in place with both sellers and purchasers of online media inventory, as well as with the entities required to support its business (e.g., office technology providers, landlords, etc.).
Risk Assessment
Given the technological focus of Index Exchange’s business, its supply chains are principally for: (i) the provision of technology to its clients; and (ii) the procurement of: (a) office and IT equipment to support its office facilities; and (b) professional services from legal, accounting, and consulting professionals to support its ongoing business. These supply chains are short and typically dependent on highly-skilled, educated workers. As a result, Index Exchange assesses the risk of Modern Slavery or human trafficking in our business and our supply chains to be very low. Nonetheless, we are devoted to ensuring our business reflects our commitment to high integrity and legally compliant practices.
With our operations, the key areas that could be affected by slavery and human trafficking are our employees, sub-contractors, and suppliers. We mitigate risks in each of these areas in the following ways:
Employees
• We verify that all employees have the right to work in their jurisdiction upon commencement of their employment.
• We make all employees aware of the terms and conditions of their employment through their contracts of employment and Index Exchange’s corporate policies which may be amended from time to time.
• We require all employees to sign a Code of Conduct and an Employee Handbook upon hire, and on an annual basis thereafter. Both the Code of Conduct and the Employee Handbook affirm our commitment to a respectful work environment, free from violence, threats or other acts of aggression.
• We review and amend our human resources policies on a regular basis, in accordance with business needs and legislative changes.
• All employees are paid into a bank or building society account in their name.
Sub-Contractors
• We require subcontractors to ensure that their employees are eligible to work in their jurisdiction.
• We require our sub-contractors to adopt and respect the same high standards that we hold for our employees, as applicable.
Suppliers
• We maintain a Signing and Spending Authority Policy which governs the review and authorization of expenses and contractual agreements with suppliers. This Policy is consistently enforced to achieve transparency with our resources and in our supply chains.
• We conduct due diligence on our suppliers and expect them to respect and adopt the same standards as Index Exchange regarding Modern Slavery and human trafficking, as applicable.
Monitoring and Reporting System
Index Exchange maintains a global whistleblower reporting program. The Index Exchange Whistleblower Protection Policy establishes procedures for all employees or third parties to report legal and ethical violations, including the suspected or actual occurrence of Modern Slavery. We offer multiple reporting options, including a helpline to report concerns anonymously. We promote these reporting options through our internal policies, communications, and mandatory compliance training.
Remediation Process
If a Modern Slavery concern is raised through any of our reporting channels, Index Exchange reviews the complaint to determine if further investigation or review is required. If appropriate, a formal investigation may be conducted and directed by the General Counsel.
If the investigation finds evidence that Modern Slavery will occur or is already occurring, remedial action will be implemented. Our first priority is to take measures to protect the safety, privacy, and wellbeing of the affected person(s). If this is not possible, Index Exchange will take further remedial actions, including severing of the business relationship.
Additional Efforts to Combat Modern Slavery
In an effort to disrupt and prevent any form of Modern Slavery, our internal advertising review team (“Exchange Quality”) will undertake efforts to remove and block all supply and demand content that they believe facilitates or coordinates the exploitation of humans or any other form of Modern Slavery.
Specifically, Exchange Quality blocks content that includes adult-oriented themes that target minors, underage or non-consensual sexual themes, advertising of compensated sexual acts or any other content that may facilitate or suggest the use of Modern Slavery or violate any applicable law. Exchange Quality enforces these prohibitions through regular review and monitoring of all supply and demand content.
Training & Awareness
To ensure a high level of understanding of the risks of Modern Slavery and human trafficking in our supply chains and our business, Index Exchange will post its Anti-Slavery Policy on our intranet, external website, and the U.K. and Australian government registries.
We conduct training on our Employee Code of Conduct which includes guidance on our Anti-Slavery Policy, to help employees identify risks or indicators related to Modern Slavery. Employees who work in customer services and sales are required to take additional awareness training on detecting and reporting corruption in supply chains.
Review
This statement will be reviewed and updated where required on an annual basis. Responsibility for compliance lies with the management team. This statement is made pursuant to section 54(1) of the U.K. Modern Slavery Act, 2015 and section 13(2) of the Australia Modern Slavery Act, 2018 and constitutes Index Exchange Limited’s slavery and human trafficking statement for the financial year ending December 31, 2023.
The statement was approved by the Index Exchange Inc. Board of Directors and covers all activities undertaken by Index Exchange’s global entities.
Jason Cicchetti
Secretary
Index Exchange