Modern Slavery Statement

Introduction

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 taken during the fiscal year to ensure to identify and prevent modern slavery and human trafficking, covering direct operations, supply chain and business relationships. This statement refers to the fiscal year ending 28 February 2025.

Explaining Modern Slavery

Modern slavery is a global crime impacting millions of individuals worldwide, cutting across age, gender, and ethnic lines. Tragically, vulnerable people from both abroad and within the UK are coerced into illegal labour in various industries, including agriculture, construction, hospitality, retail, manufacturing, and beyond.

Our perspective

As an international data science organization, dunnhumby believes the risk of modern slavery within our business to be very low. Nevertheless, we are mindful that identifying modern slavery can be challenging, particularly when it occurs within complex supply chains. As a result, no business can be considered immune to this issue.

dunnhumby is committed to ensure that modern slavery, human trafficking, bonded and forced labor have no place in or around our business. We encourage an open and honest culture that requires all our colleagues to always act ethically and with integrity.

Ethical behaviour is of utmost importance to us and begins with our Code of Business Conduct. Our CCCP values of Curiosity, Courage, Collaboration, and Passion, are the pillars of our culture helping us do the right thing when faced with difficult decisions, which includes not tolerating behaviour within dunnhumby or by suppliers that is illegal, unethical or which breaches human rights.

Our Code of Business Conduct and associated processes/policies support our approach to identify and mitigate against this risk.

Organization structure and supply chains

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 25 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 1000 active suppliers. Our main categories of purchasing spend are technology, print and creative, property, facilities, and professional services. Most of these active suppliers provide services from the UK and Europe.

We are committed to operating with the highest level of ethics and integrity in everything we do. This means ensuring our suppliers are committed to ethical employment practices. We abide by all applicable anti-slavery and human trafficking laws, including the U.K. Modern Slavery Act of 2015.

Policies in relation to slavery and human trafficking

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 colleagues, contractors, 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 center of how we behave. Acting legally and ethically and following our policies are some of the ways in which we ensure that everyone is treated fairly and consistently, creating a workplace and business environment that is open, transparent and trusted.

Our business is built on being the champion for customers. This value embedded throughout our business resonates with our employees, and frames how we expect the suppliers we work with to engage with their colleagues, customers, and suppliers to conduct business responsibly. We therefore seek to do business only with suppliers who have similar values and ethics as ourselves.

To ensure responsible supply chain management and sustainable procurement, we require potential suppliers to provide information relating to their anti-modern slavery and human trafficking policies as part of dunnhumby’s Request for Proposal (RFP) process.

We also have in place a 'Procurement policy' for how we deal with suppliers and a ‘Supplier code of conduct’ making clear the standards we expect.
dunnhumby does not tolerate slavery, human trafficking, bonded labour, forced labour, child labour or child exploitation under any circumstance. We have implemented several 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.

Due diligence processes

The implementation of our policies and procedures includes due diligence on suppliers that we engage with, in accordance with our procurement policy.
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; and
• whether there are any issues in the country where services are provided, which may have an impact further down the supply chain, for example, in relation to the sourcing of materials and components.

We particularly focus our efforts to review and assess high and medium risk suppliers. A full due diligence assessment is carried out before any new supplier is on-boarded. This assessment covers a range of topics including regulatory and legal compliance, bribery and corruption, HR, and business integrity.

We review our global supplier base on an ongoing basis to ensure that due diligence is carried out on all existing suppliers. In the past 12 months we have continued to improve our due diligence processes for new suppliers. Over the past 12 months, we have identified all high-risk suppliers and completed a review of their contracts.

Risk Assessment and Management

dunnhumby has put in place several procedures to ensure that modern slavery does not occur in our business or supply chains.

• Recruitment and Employment

  dunnhumby has comprehensive recruitment processes and procedures in place, including conducting eligibility to work in the UK checks for all employees, safeguarding against human trafficking or forced labour. All colleagues receive Terms and Conditions which are regularly reviewed in line with employment laws and best practices.

  Where we require the use of agency labour, dunnhumby only uses reputable employment agencies, the majority of which we have long-standing relationships with. If we engage any temporary staff from agencies, we work closely with the agency to ensure the necessary due diligence is conducted prior to their appointment, to safeguard against modern slavery.

• Whistleblowing

  We also recognize the importance of effective grievance mechanisms in mitigating the risk of modern slavery.

  dunnhumby has a comprehensive whistleblowing policy (Speak Up Policy) which encourages all our colleagues, suppliers, 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 Speak Up Policy is designed for all our colleagues and suppliers to confidently speak up and easily report without any inconvenience. These resources are available in six languages covering all our key operating regions. Additionally, an awareness campaign is actioned annually to support this program.

  NAVEX Global Inc., an independent external organisation operates our Ethics Hotline. They provide details of each report to our General Counsel, which is then reviewed and investigated at appropriate levels within dunnhumby.

  Reporters have the option to remain anonymous to empower them to report concerns in confidence without risk to their employment or fear of any form of retaliation. The link to the Ethics Hotline is available on our website and on our employee intranet.

Key Performance Indicators to measure effectiveness of steps being taken

In addition to publishing the Modern Slavery Statement, we report any critical breaches of our policies to our Risk & Compliance Committee and to Tesco Group. In FY24, we did not identify any indicators of modern slavery in our own operations or supply chains.

We also monitor progress against the commitments we make within our Modern Slavery Statement each year.

In FY25 we will continue to provide ongoing training on modern slavery risks to our procurement teams, supplier management colleagues and internal business owners. We will further strengthen our ongoing due diligence processes for existing suppliers globally and improve awareness of our Code of Business Conduct amongst our suppliers.

Training and awareness

We acknowledge the fact that educating and supporting our colleagues in managing ethical issues and nurturing compliance with all the applicable laws is fundamental in identifying and managing potential human rights and modern slavery risks. Our current annual and onboarding training and our Code of Business Conduct embeds the same, specifically focusing on:

• Conducting business in full compliance with all applicable laws and regulations; and
• Understanding and complying with high ethical standards and integrity and taking stand to correct or prevent any improper activity

We have refreshed our annual training over the past 12 months and 100% of our colleagues have completed it.

Our Way Forward

We will continue to strengthen our approach to managing the risk of Modern Slavery within our business. Our ambitions include:

• Continuing to provide bespoke training on modern slavery risks to key colleagues including our procurement team, supplier management colleagues and internal business owners.
• Further strengthening our on-going due diligence process for existing suppliers, globally, prioritizing those identified as higher risk.
• Improving awareness and understanding of our Code of Business Conduct and associated company policies amongst our supplier population, including a Supplier Code of Conduct and training.

We end this by stating that the organisation remains committed to improving its practices to combat modern slavery and human trafficking and abide by all relevant laws.

ROB BLISS

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Rob Bliss, CFO dunnhumby Limited