Modern Slavery Statement
ALM Media, LLC & American Lawyer Media International Limited Slavery and Human Trafficking Statement for the Financial Year ending 31 December 2018.
1.1 This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps which ALM Media LLC and American Lawyer Media International Limited (collectively referred to in this statement as “ALM”) have taken in this financial year to combat slavery and human trafficking.
1.2 ALM is committed to preventing slavery and human trafficking in our supply chains. Taking these steps has strengthened our resolve still further and the tools it provides us with will empower us to do more than ever before in pursuit of this goal.
2.1 ALM is a publisher of print and digital B2B editorial content and intelligence, providing our services and publications to businesses involved in the legal, financial services, benefits, consulting, insurance and real estate industries. ALM Media LLC is the parent company of the ALM group (which incorporates our UK subsidiaries American Lawyer Media International Limited, Global Leaders in Law Limited and Legal Week Limited. The ALM group’s business also includes organising conferences and events to serve its target audiences.
2.2 Collectively, the ALM group has over 600 employees and operates globally, with employees in in North America, Asia and Europe.
2.3 ALM Media LLC has a global annual turnover in excess of £36 million, including our subsidiaries.
3. Our Supply Chains
Our immediate suppliers are as follows: those providing IT platforms that enable us to deliver our digital services and suppliers of editorial content, such as freelancers and picture agencies. We also organize events in various parts of the world that are dependent on third party providers of venues and facilities, which also source goods and services from further down the supply chain.
4. Our Policies on Slavery and Human Trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Corruption and Bribery Policy and Anti-Facilitation of Tax Evasion Policy reflect our commitment to acting ethically and with integrity in all our business relationships. This also includes the implementation and enforcement of effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains.
5. Due Diligence Processes for Slavery and Human Trafficking
5.1 We have put in place systems to:
5.1.1 Identify and assess potential risk areas in our supply chains.
5.1.2 Mitigate the risk of slavery and human trafficking occurring in our supply chains.
5.1.3 Monitor potential risk areas in our supply chains.
5.2 As part of our initiative to identify and mitigate risk we have noted the following:
5.2.1 Due to the nature of our activities, our suppliers are largely in low risk sectors. Most of our suppliers are based in countries which have a relatively low risk of slavery and human trafficking, such as the U.K., the U.S. and Canada.
5.2.2 However, we have identified suppliers in the food and drink / hospitality sector, which have a relatively high risk of slavery and human trafficking, particularly for events located in countries in which the risk of forced labour is greater than in the UK, such as in countries in Africa and Asia.
6. Supplier Adherence to Our Values
6.1 ALM expects all suppliers and any subcontractors to respect and conform to our fundamental values as conditions for mutual business.
6.2 We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have taken the following steps:
6.2.1 We are encouraging best practices around due diligence when selecting new suppliers.
6.2.2 We are mitigating the risks in high risk sectors by requiring that our contracts with venues at which we hold our events in high-risk areas include written warranties and assurances regarding the venue’s implementation of appropriate systems of due diligence and actions to ensure that there is no modern slavery or human trafficking by the venue or their subcontractors.
7.1 To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.
7.2 Staff are expected to be alert to the risks, however small, in our business and in the wider supply chain. Staff must report concerns and management are expected to act upon them.
7.3 We have introduced a whistleblowing policy so that people can raise concerns about slavery and human trafficking in our supply chains.
8. Further Steps
8.1 Following a review of the effectiveness of the steps we have taken this year to ensure that here is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking:
8.1.1 We will continue to develop and implement a plan for working with our suppliers to combat slavery and human trafficking.
8.1.2 We will produce a code of conduct for suppliers, setting out our expectations from them with regard to slavery and human trafficking. We will make this code of conduct available to all employees on our Company intranet and will provide training on the policy.
8.1.3 Once implemented, should a supplier fail to fulfil the minimum standards outlined in our Code, we reserve the right to terminate the business supplier or elect not to renew its contract.
8.1.4 We will periodically review the effectiveness of the of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains by continuously improving any policies, procedures and systems that we have implemented.
This statement was approved by the Board of Directors on July 24, 2018.