Assessing risk-our due diligence
The Flybuys modern slavery working group is led by the Flybuys legal and procurement teams who are supported by external human rights experts. During the current reporting period the working group prepared a modern slavery compliance plan which documented key actions for completion in the current reporting period.
During the current reporting period, Flybuys utilised the risk assessment tools developed during the first reporting period to deepen our engagement with suppliers assessed as at higher risk of modern slavery in the first reporting period. For example, this guided our engagement with the facilities management and cleaning suppliers in our new office complex.
The outcome of this assessment of suppliers higher risk of modern slavery has enabled Flybuys to prepare plan for supplier consultation.
Supplier consultation process
During the first reporting period, Flybuys' focus was to consult and engage with our overseas suppliers and our redemption providers via the supplier consultation process, which incorporates a questionnaire seeking information about supply chains and work practices. This process is an important way for us to gain further information about our suppliers and understand whether there may be any risks of modern slavery in their operations and supply chain.
During the current reporting period, in addition to pursuing engagement from the small number of suppliers who did not respond to our request for information during the first reporting period, we focused the due diligence process on the following suppliers: office suppliers, staff augmentation service providers and marketing and ancillary marketing product service providers. Selection of these categories of suppliers was based on a risk rating which Flybuys applied to the supply chain, taking into account the factors set out above.
We were pleased with the level of engagement and noted that many of our suppliers either have in place or are developing their own protocols and policies to address modern slavery risks.
Vendor onboarding
During the current reporting period Flybuys implemented a new vendor onboarding process which incorporates modern slavery considerations into the due diligence process. This will further assist Flybuys in monitoring risks of modern slavery in its supply chain and allow Flybuys to engage with suppliers at an even earlier stage to ensure appropriate remediation steps are put in place if any risks are identified.
Addressing risk-our policies, procedures and training
During the current reporting period, Flybuys finalised and implemented a Responsible Procurement Policy and a set of Supplier Minimum Standards, which were both prepared in draft form during the first reporting period and subsequently approved by the Flybuys Board. These documents were rolled out within the organisation and are located on the Flybuys employee online portal.
Wherever possible, when any new suppliers are engaged we utilise our standard form contracts and documents, which contain modern slavery clauses. These impose contractual commitments on our material suppliers to require them to meet minimum standards related to prevention of modern slavery and ongoing due diligence in their supply chains. We have been pleased that suppliers engaged over the course of the current reporting period have been generally supportive of such inclusions in the contracts. This was the case when Flybuys issued new contracts to all of its rewards suppliers, with many of whom Flybuys has had a long term business relationship, as a result of the launch of the new Flybuys Rewards Store during the current reporting period. All suppliers executed contracts which contain relevant clauses addressing modern slavery and a contractual commitment to meeting the Supplier Minimum Standards.
The Flybuys Whistleblower Policy sets out a process for Flybuys representatives to raise concerns about improper conduct. Under the Whistleblower Policy persons are required to report failures of persons to comply with legal or regulatory obligations (such as modern slavery and human rights law), as well as conduct potentially damaging to Flybuys (which could include unsafe work practices and modern slavery risks). Under the Whistleblower Policy, contact details are provided for concerns to be raised, which includes an anonymous hotline managed by a third party. The Whistleblower Policy is available publicly on the Flybuys website and is also on the Flybuys employee online portal. In addition, there is a mandatory training module for all Flybuys employees to support employees in understanding when and how to report misconduct and to maintain a culture that encourages the reporting of wrongdoing. Over the current reporting period, Flybuys has not received any complaints in respect of modern slavery.
The Flybuys modern slavery working group will continue to engage with the wider Flybuys business in the next reporting period to consider whether there may be further opportunities to improve or implement new policies and procedures.
Our training and capacity building
During the current reporting period, we launched our employee online training platform which includes a mandatory learning module on modern slavery. The modern slavery module has been completed by the majority of current team members and is mandatory for any new employees who join Flybuys. This training raises awareness of modern slavery and our anti-slavery policies and procedures. In addition to modern slavery, other mandatory training modules that have been implemented during the current reporting period which further promote ethical business practices across the organisation include whistleblowing training (as noted above), Code of Conduct training (which includes anti-bribery) and positive culture training. The Flybuys People Experience Team monitor and report to Flybuys Leadership Team members on training compliance and follow up with any individuals if training is outstanding. Flybuys will continue to monitor the effectiveness of the training and identify whether further training may be beneficial.
Remediation plan
Flybuys recognises the importance of educating and supporting its employees to not only identify potential modern slavery risks but also to understand what actions may be appropriate in the event a risk was found in the Flybuys supply chain.
During the current reporting period, a draft Modern Slavery Remediation Flowchart and guidance note was prepared by Flybuys and will be incorporated into the Flybuys Crisis Management Plan. Whilst it is recognised that each situation must be addressed on its merits, the Remediation Plan will be an important tool to guide Flybuys in dealing with any instances of modern slavery in our supply chain.
While still in draft, the Remediation Plan provides for Flybuys' actions in respect of safeguarding potential survivors of modern slavery, ensuring that any response is appropriate and proportionate and that survivors are appropriately remediated. Over the next reporting period, Flybuys will ensure that key employees are trained in respect of our Remediation Plan. We will also engage with our shareholders and program participants and partners to confirm they are implementing a plan of action to cease and address impacts of modern slavery where discovered or alleged to be in their supply chains.
Technology solutions
Flybuys recognises that utilising technology solutions may provide opportunities to strengthen practices and procedures in relation to identifying risks of modern slavery. During the next reporting period, Flybuys will explore what, if any, technology solutions may be available to assist us to manage and identify the risk of modern slavery.
Assessing the effectiveness of our actions
It is important for Flybuys to ensure that the actions we are taking are effective in helping to identify and mitigate the risks of modern slavery. Through the procurement team and contract managers, we continue to have an open dialogue with our suppliers which is demonstrated in the responsiveness to our due diligence processes, whether that be at the commencement of our contractual relationship or as we seek to understand more about our suppliers through our supplier questionnaires.
As a result of the roll out of our online training program, all team members at Flybuys should understand how to identify risks of modern slavery in our supply chain and the key polices and processes underpinning Flybuys' commitment to mitigate risks of modern slavery. Completion of the mandatory training is monitored by the Flybuys People Experience Team.
As already noted, during the current reporting period Flybuys utilised an improved supplier onboarding platform, which will allow Flybuys to engage with suppliers regarding supply chain and modern slavery at an early stage. The effectiveness of implementing this new procedure as it relates to managing modern slavery risks will be monitored into the next reporting period by collating regular reports of new vendors, assessing for any potential risks identified and following up as appropriate.