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FY20 Modern Slavery Statement

ZPG Limited

Slavery and Human Trafficking Statement for the 2020 Financial Year

We are committed to improving our practices to combat slavery and human trafficking. We have published this group statement in accordance with section 54 of the Modern Slavery Act 2015 (the “Act”) on behalf of ZPG Limited and the following subsidiaries: Dot Zinc Limited, Uswitch Limited and Zoopla Limited (“we”, “us” or “our”). It sets out the steps we have taken during the year to prevent modern slavery and human trafficking in our supply chains and in our business generally.

Our Structure, Business and Supply Chain

We own and operate some of the UK's most trusted digital platforms including Bankrate, Hometrack, Money.co.uk, PrimeLocation, Property Software Group, Uswitch and Zoopla.

We create value by investing in marketing our brands and growing our audiences, and by developing the best products and platforms in order to engage our consumers and partners.

Consumers increasingly use and rely on our platforms in search of real‐time information about the property and comparison markets. Similarly, property professionals and home services suppliers use our platforms to reach a transaction‐ready audience and market their products and services.

Our supply chains include the following:

  • Facilities: maintenance and cleaning services.
  • Marketing: media advertising and market research services.
  • People: recruitment and training services.
  • Professional services: advisory and consultancy services.
  • Technology: external data centres, data providers, IT infrastructure, hardware providers, cyber security services and software suppliers.

Our Policies in relation to Slavery and Human Trafficking

We respect human rights and the integrity of individuals. We comply with all relevant laws in the way we run our businesses.

We have in place a whistleblowing policy which applies to all of our employees, officers, consultants, casual workers and agency workers. This “Speak Up” policy encourages everyone working for us to report any malpractice or illegal acts, including suspicion of modern slavery and human trafficking, or omissions or matters of similar concern by other employees or former employees, contractors, suppliers, partners or advisers using a prescribed reporting procedure.

We engage an external and independent third party based in the UK to provide a reporting facility for individuals to bring these areas of concern to our attention in a secure and confidential manner. This facility includes access to a 24/7 confidential whistleblowing telephone line.

We are also committed to conducting our businesses ethically and lawfully which includes ensuring, as far as possible, that any third parties who act for us share this commitment. The company’s “Working with Third Parties” policy is in place to help to identify and mitigate risks associated with the third parties who perform services for us or on our behalf. This includes guidance on undertaking appropriate due diligence on existing or prospective third parties based on identifiable risks.

We have group‐wide template clauses which are included in appropriate contracts to allow contracting parties to formally acknowledge, commit to and abide by applicable anti‐slavery and human trafficking legislation.

Due Diligence and Contracting Practices

We conduct due diligence on our suppliers by requesting information from them (which includes information about the steps they take to ensure there is no modern slavery or human trafficking in their business or supply chains). We keep our due diligence processes under constant review. For the property services side of the business our processes were last reviewed and updated in February 2020 and for the comparison services side of the business our processes were last reviewed and updated in July 2020.

We consider key suppliers’ responses to our due diligence requests as part of our decision‐making processes when it comes to using new suppliers. We take appropriate action and, if necessary, delay or cancel appointing a new supplier unless the supplier’s systems and controls are satisfactory.

Assessing and Managing Risk

Due to the nature of our businesses, our supply chains are limited and we operate with only a small number of suppliers.

Nevertheless, we select some of our key suppliers based on ethical certifications (some of which – for example, the Fairtrade certification – impose obligations on suppliers to eliminate modern slavery). These suppliers must provide evidence of their ethical certification before we conclude contracts with them.

We also seek contractual assurances from key suppliers in relation to modern slavery and human trafficking compliance, particularly where those suppliers operate in, or make us part of, supply chains which present higher risks of modern slavery or human trafficking.

Policies

We have continued to provide advice and guidance to the relevant commercial teams with direct responsibility for entering into supplier contracts.

We comply with all relevant employment legislation and have a number of policies that adhere to internationally recognised human rights principles including:

  • Group Recruitment Policy;
  • Anti-Bribery and Corruption Policy; and
  • Speak-Up Policy.

Effectiveness

 ZPG has implemented targets and key performance indicators across the business for compliance with the Act to measure the effectiveness of the steps being taken. These include:

 Reviewing any investigations undertaken into reports of modern slavery (including any concerns raised under the “Speak Up” policy) and actions taken in response;

  • Reviewing our centralised supplier due diligence for effectiveness across our top suppliers; and
  • Reviewing staff training levels on modern slavery risks for key team members.

Training

All employees receive induction training including an outline of our key policies. Key policies are hosted on our intranet sites and employees are reminded of their responsibilities. Where relevant, compliance related matters are highlighted to all employees through our regular employee communication channels.

 

Our commitment

We are committed to continuously improving our practices to identify and eliminate any slavery and human trafficking in our business and supply chains, and to acting ethically and with integrity in all of our business relationships.

We use a wide range of suppliers who supply goods for sale, provide services at events, and support our operations.

Approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the group’s slavery and human trafficking statement for the financial year ending 31 December 2020. It was approved by the board on 29 June 2021.

 

 Charles Bryant

Director

ZPG Limited

Date: 29 June 2021

_________________________________________________________________________________________________________________________________________________

 

FY19 Modern Slavery Statement

ZPG Limited

 

Slavery and Human Trafficking Statement for the 2019 Financial Year

We are committed to improving our practices to combat slavery and human trafficking. We have published this statement in accordance with section 54 of the Modern Slavery Act 2015 (the “Act”) on behalf of ZPG Limited and its subsidiaries* (“we”“us” or “our”). It sets out the steps we have taken during the year to prevent modern slavery and human trafficking in our supply chains and in our business generally.

Our Structure, Business and Supply Chain

We own and operate some of the UK's most trusted digital platforms including Zoopla, uSwitch, PrimeLocation, Money.co.uk, Bankrate, Property Software Group and Hometrack.

We create value by investing in marketing our brands and growing our audience and by developing the best products and platforms to engage our consumers and partners.

Consumers increasingly use and rely on our platforms in search of real‐time information about the property and comparison markets. Similarly, property professionals and home services suppliers use our platforms to reach a transaction‐ready audience and market their products and services.

Our supply chains include the following:

  • People: recruitment and training services.
  • Marketing: media advertising and market research services.
  • Professional services: advisory and consultancy services.
  • Facilities: maintenance and cleaning services.
  • Technology: external data centres, data providers, IT infrastructure, hardware providers, cyber security services and software suppliers.

Our Policies in relation to Slavery and Human Trafficking

We respect human rights and the integrity of individuals. We comply with all relevant laws in the way we run our business.

We have in place a whistleblowing policy which applies to all of our employees, officers, consultants, casual workers and agency workers. This “Speak Up” policy encourages everyone working for us to report any malpractice or illegal acts, including suspicion of modern slavery and human trafficking, or omissions or matters of similar concern by other employees or former employees, contractors, suppliers, partners or advisers using a prescribed reporting procedure.

We engage an external and independent third party based in the UK to provide a reporting facility for individuals to bring areas of concern to our attention in a secure and confidential manner. This facility includes access to a 24/7 confidential whistleblowing telephone line.

We are also committed to conducting business ethically and lawfully and this includes ensuring, as far as possible, that any third parties who act for us share this commitment. The Company’s “Working with Third Parties” policy is in place to help to identify and mitigate risks associated with the third parties who may perform services for or on behalf of us. This includes guidance on undertaking appropriate due diligence on existing or prospective third parties based on identifiable risks.

We have group‐wide template clauses which are included in appropriate contracts which allow contracting parties to formally acknowledge, commit to and abide by applicable anti‐slavery and human trafficking legislation.

Due Diligence and Contracting Practices

We conduct due diligence on our suppliers by requesting information from them (which includes information about the steps they take to ensure there is no modern slavery or human trafficking in their business or supply chains). We keep our due diligence process under constant review, and it was last reviewed and updated in April 2020.

We consider key suppliers’ responses to our due diligence requests as part of our decision‐making processes when it comes to using new suppliers. We take appropriate action and, if necessary, delay or cancel appointing a new supplier unless the supplier’s systems and controls are satisfactory.

Assessing and Managing Risk

Due to the nature of our businesses, our supply chains are limited and we operate with only a small number of suppliers.

Nevertheless, we select some of our key suppliers based on ethical certifications (some of which – for example, the Fairtrade certification – impose obligations on suppliers to eliminate modern slavery). These suppliers must provide evidence of their ethical certification before we conclude contracts with them.

We also seek contractual assurances from key suppliers in relation to modern slavery and human trafficking compliance, particularly where those suppliers operate in, or make us part of, supply chains which present higher risks of modern slavery or human trafficking.

Policies

We have continued to provide advice and guidance to the relevant commercial teams with direct responsibility for entering into supplier contracts.

We comply with all relevant employment legislation and have a number of policies that adhere to internationally recognised human rights principles including:

  • Group Recruitment Policy;
  • Anti-Bribery and Corruption Policy; and
  • Speak-Up Policy.

 

Our commitment

We are committed to continuously improving our practices to identify and eliminate any slavery and human trafficking in our business and supply chains, and to acting ethically and with integrity in all our business relationships.

We use a wide range of suppliers who supply goods for sale, provide services at events and support our operations.

Approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 30 September 2019. It was approved by the board on 3 August 2020.

 

Charles Bryant

Director

ZPG Limited

Date: 3 August 2020

*ZPG Limited, Zoopla Limited and uSwitch fall within the scope of section 54(2) of the Act

_________________________________________________________________________________________________________________________________________________

FY18 Modern Slavery Statement

ZPG Limited 

Slavery and Human Trafficking Statement for the 2018 Financial Year 

We have published this statement in accordance with section 54 of the Modern Slavery Act 2015 (the “Act”) on behalf of ZPG Limited and its subsidiaries* (“we”, “us” or “our”). It sets out the steps we have taken during the year to prevent modern slavery and human trafficking in our supply chains and in our business generally.

Our Structure, Business and Supply Chain 

We own and operate some of the UK's most trusted digital platforms including Zoopla, uSwitch, PrimeLocation,  Money.co.uk, Bankrate, Property Software Group and Hometrack. 

We create value by investing in marketing our brands and growing our audience and by developing the best products and platforms to engage our consumers and partners. 

Consumers increasingly use and rely on our platforms in search of real‐time information about the property and comparison markets. Similarly, property professionals and home services suppliers use our platforms to reach a  transaction‐ready audience and market their products and services

Our supply chains include the following: 

  • People: recruitment and training services.  
  • Marketing: media advertising and market research services.  
  • Professional services: advisory and consultancy services.  
  • Facilities: maintenance and cleaning services.  
  • Technology: external data centres, data providers, IT infrastructure, hardware providers, cyber security services and software suppliers. 

Our Policies in relation to Slavery and Human Trafficking 

We respect human rights and the integrity of individuals. We comply with all relevant laws in the way we run our business. 

We have in place a whistleblowing policy which applies to all of our employees, officers, consultants, casual workers, and agency workers.  This  “Speak  Up” policy encourages everyone working for us to report any malpractice or illegal acts, including suspicion of modern slavery and human trafficking, or omissions or matters of similar concern by other employees or former employees, contractors, suppliers, partners or advisers using a  prescribed reporting procedure. 

We engage an external and independent third party based in the UK to provide a reporting facility for individuals to bring areas of concern to our attention in a secure and confidential manner. This facility includes access to a  24/7 confidential whistleblowing telephone line. 

We are also committed to conducting business ethically and lawfully and this includes ensuring, as far as possible, that any third parties who act for us share this commitment. The  Company’s  “Working with Third Parties” policy is in place to help to identify and mitigate risks associated with the third parties who may perform services for or on behalf of us. This includes guidance on undertaking appropriate due diligence on existing or prospective third parties based on identifiable risks. 

*ZPG Limited, Zoopla Limited and uSwitch fall within the scope of section 54(2) of the Act 

We have group‐wide template clauses which are included in appropriate contracts which allow contracting parties to formally acknowledge, commit to and abide by applicable anti‐slavery and human trafficking legislation.

Due Diligence and Contracting Practices 

We conduct due diligence on our suppliers by requesting information from them (which includes information about the steps they take to ensure there is no modern slavery or human trafficking in their business or supply chains). We keep our due diligence process under constant review, and it was last reviewed and updated in April
2019.

We consider suppliers’ responses to our due diligence requests as part of our decision‐making processes when it comes to using new suppliers. We take appropriate action and, if necessary, delay or cancel appointing a new supplier unless the supplier’s systems and controls are satisfactory

Assessing and Managing Risk

Due to the nature of our businesses, our supply chains are limited and we operate with only a small number of suppliers.

Nevertheless, we select some of our suppliers based on ethical certifications (some of which – for example, the Fairtrade certification – impose obligations on suppliers to eliminate modern slavery). These suppliers must provide evidence of their ethical certification before we conclude contracts with them.

We also seek contractual assurances from suppliers in relation to modern slavery and human trafficking compliance, particularly where those suppliers operate in, or make us part of, supply chains which present higher risks of modern slavery or human trafficking.

Training

We have continued to provide advice and guidance to the relevant commercial teams with direct responsibility for entering into supplier contracts. We will be introducing specific modern slavery and human trafficking guidance into our induction documents for new joiners.

Approval

This statement was approved by the Board of Directors of the Company on 11 June 2019.

 

_________________________________________________________________________________________________________________________________________________

FY17 Modern Slavery Statement

ZPG Limited

Slavery and Human Trafficking Statement for the Financial Year 2017

This statement has been published in accordance with section 54 of the Modern Slavery Act 2015 and sets out the steps taken by the Company and the rest of its group companies during the year to prevent modern slavery and human trafficking in its supply chains and or in any part of its business.

Structure, Business and Supply Chain

The Company owns and operates some of the UK's most-trusted digital platforms including Zoopla, uSwitch, PrimeLocation, money.co.uk, Property Software Group and Hometrack. The Company creates value by investing in marketing its brands and growing its audience and by developing the best products and platforms for its consumers and partners to engage with.

Consumers increasingly use and rely on the Company’s platforms in search of real-time information about the property and comparison markets. Similarly, property professionals and home services suppliers increasingly rely on the Company’s platforms to reach a transaction-ready audience and market their products and services.

Due to the nature of the Company’s businesses, its supply chain is limited and it operates with only a small number of suppliers.

Policies in relation to Slavery and Human Trafficking

The Company respects human rights and the integrity of individuals and complies with all relevant laws in the way it runs its business. 

The Company has in place a whistleblowing policy which encourages employees to report any malpractice or illegal acts, including suspicion of modern slavery, or omissions or matters of similar concern by other employees or former employees, contractors, suppliers, partners or advisers using a prescribed reporting procedure.

The Company is committed to conducting business ethically and lawfully and this includes ensuring, as far as possible, that any third parties who act for the Company share this commitment. The Company’s “Working with Third Parties” policy is in place to help to identify and mitigate risks associated with the third parties who may perform services for or on behalf of the Company. This includes undertaking due diligence in potential acquisition situations.

Due Diligence Processes

The Company conducts a due diligence process with partners which requests information from partners and third parties.

Partners are requested to provide their internal policies (including Modern Slavery policy/statement) and accounting information. If policies and/or accounting information is not adequate the Company will take appropriate action and if necessary, hold back on-boarding a partner until their systems and controls are satisfactory, or refuse to work with a partner altogether.

Approval

This statement was approved by the Board of Directors of the Company on 22 May 2018.