Modern Slavery Statement


dunnhumby Limited is publishing this statement under the provision of the Modern Slavery Act 2015 (the ‘Act’) on behalf of the dunnhumby Group. The Act requires dunnhumby to state the actions we have taken during the financial year to ensure modern slavery is not taking place in our operations and supply chains. This statement refers to the financial year ending 28 February 2019.

As an international data science organisation, dunnhumby believes the risk of modern slavery within our business to be relatively low. However, modern slavery can be challenging to identify, particularly when it occurs within complicated supply chains and therefore no business can be considered immune. dunnhumby is committed to ensuring that modern slavery, human trafficking, bonded and forced labour have no place in or around our business. dunnhumby encourages an honest and open culture and requires all employees to act with integrity at all times. Our Code of Business Conduct and associated processes/policies support our approach to tackling any risk.

About Our Business

A world-leader in customer science, dunnhumby has pioneered the use of big data to drive growth for retailers and brands since 1989. With more than 35 offices in more than 28 countries, dunnhumby’s strategic process, proprietary insights and multichannel media capabilities deliver competitive advantage for FMCG and retail clients.

dunnhumby currently has a supply base of circa 2000+ active suppliers. Our main categories of purchasing spend are technology, print and creative, property and facilities and professional services. The majority of these active suppliers provide services from the UK and Europe, with only a small percentage from the rest of the world.

dunnhumby Policy

dunnhumby understands that people lie at the heart of this legislation. We have a responsibility to respect the human rights of, and an opportunity to make a difference to, our employees, customers, the communities we operate in and the people who work throughout our supply chain.

Our Code of Business Conduct places our core values of courage, passion, collaboration and curiosity at the centre of how we behave toward our clients, clients’ customers, suppliers and to each other. Acting legally and ethically and following our policies are some of the ways in which we ensure that we always do our best for our clients, our client’s customers and for each other. Our business is built on being the champion for customers. This value is embedded throughout our business, resonates with our employees and also frames how we expect the suppliers we work with to engage with their colleagues, customers and suppliers. We therefore seek to do business only with suppliers who have similar values and ethics as ourselves.

dunnhumby does not tolerate slavery, human trafficking, bonded labour, forced labour, child labour or child exploitation.

We have implemented a number of policies which allow us to manage human rights within our business and externally with our suppliers, including our Code of Business Conduct, and our procurement and supplier management processes. The Code of Business Conduct can be found on the dunnhumby website.

Procedures adopted to assess and manage slavery and human tarfficking risk

As a data science services organisation, we believe the risk of modern slavery within our own business to be relatively low. We recognise, however, that through our supply chain we could be indirectly exposed to the risk of modern slavery and human trafficking.

Aligned with the approach taken elsewhere in the Tesco Group, for our key suppliers we have sought to identify issues or supply chains where workers are more vulnerable to abuses like slavery.

As part of this process we have considered:

  • the types of service provided by our suppliers
  • the type of labour used for example permanent or agency
  • whether there are any known issues in the country of origin of our suppliers
  • whether there are any issues in the country where services are provided, which may feature further down the supply chain for example in relation to the sourcing of materials and components.

dunnhumby has put in place a number of procedures to ensure that modern slavery does not occur in our business or supply chains:

1. Supply Chain

dunnhumby has 2000+ key active suppliers, the majority of which provide services from within the UK.

Where third parties are identified as being key suppliers to dunnhumby, a full due diligence assessment is carried out before the supplier is on-boarded. This assessment covers a range of topics including regulatory & legal compliance, HR and integrity.

2. Recruitment and Employment

dunnhumby has comprehensive recruitment processes and procedures in place, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or forced labour. The majority of our colleagues are full time and all colleagues have Terms and Conditions which are regularly reviewed in line with employment law and best practice.

In addition, dunnhumby only uses reputable employment agencies. We have long-standing relationships with the majority of these agencies and we are assured of their practices from previous experience and their reputation in the marketplace. If we engage any temporary staff from agencies, they are always thoroughly checked prior to their appointment which safe guards against modern slavery.

3. Education, Training and Ethical Standards

In addition to having suitable policies in place, dunnhumby understands that a key part of our commitment to the Act is to ensure all our employees understand and comply with high ethical standards and integrity. We embed this in our business via the dunnhumby values, our Code of Business Conduct and annual training to support our employee’s understanding of managing ethical issues and nurturing compliance with all laws.

4. Whistleblowing

dunnhumby has a comprehensive whistleblowing policy (Speak Up Policy) which encourages all our employees and stakeholders to speak out if they have concerns about any activity, breach of law, breach of our Code of Business Conduct, dangers to the public and any concealment of information. Our policy is designed to make it easy for all colleagues to speak up and report anonymously without any risk to their employment or suffering any form of retribution.

Next Steps:

Over the next 12 months, we will continue to strengthen our approach to managing the risk of Modern Day Slavery within our business. Our ambitions include:

  • Further training on modern slavery risks to our procurement and supplier management colleagues
  • Strengthening our on-boarding and due diligence process for our suppliers outside of the UK


Joanne Wilson, CFO dunnhumby Limited