Modern Slavery and Human Trafficking Transparency Statement

This statement is provided by Projectline Limited, a subsidiary of Yesler, Inc. (collectively referred to in this Statement as the “Yesler Group”, “we”, “us” or “our”). It is made in accordance with the UK Modern Slavery Act 2015 to describe the steps taken by the Yesler Group to combat modern slavery and human trafficking.

Accountability and transparency are two of our key corporate values and this statement demonstrates our commitment to ethical behaviour by implementing and improving upon practices designed to combat modern slavery.

What is Modern Slavery?

Modern slavery is an international crime which affects an estimated 30 million individuals around the world but remains a hidden blight on our global society. Victims of any age, gender, and ethnic background have been, and continue to be, forced to work illegally against their will across many different sectors including agriculture, hospitality, construction, retail, and manufacturing. We have a responsibility to be alert to the risks, however small these may be, in our business and in our wider supply chain.

Our Business

The Yesler Group is a B2B marketing agency that blends strategy, creativity, and technology to build demand, engage B2B clients, and grow our clients’ revenue.

Through our operating companies, the Yesler Group employs more than 420 people working in four offices in four countries. Our parent company, Yesler, Inc., employs approximately 401 people in offices across the United States.

The core of our supply chain consists of people, industries, and sectors that are generally understood to be low risk for slavery or human trafficking practices. We recognize that certain sectors in our supply chain (such as office equipment suppliers, office cleaning, facilities management services, waste management services, couriers, and the food and beverage industry) may be at a higher risk. We are committed to monitoring our supply chain and will determine appropriate steps in the event that we recognise there may be a higher risk of slavery or human trafficking.

Our Policies & Commitments

We do not tolerate any form of modern slavery or human trafficking in any part of our business.

The Yesler Group is committed to implementing and improving upon practices to combat modern slavery and human trafficking in our supply chains and throughout our business.

Our policies and commitments, along with the due diligence, training, and reporting steps described in this statement reflect our ongoing commitment to act ethically and with integrity in our business relationships and to monitor our internal systems to prevent slavery and human trafficking in our business and supply chains.

We observe all international standards and principles relating to human rights within our business, including the International Bill of Human Rights, the UN Guiding Principles on Business and Human Rights, the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work, and the Children’s Rights and Business Principles.

Our policies are developed within relevant departments following a process of stakeholder consultation, cross-departmental information sharing, and senior management review and approval. We provide a clear policy framework which is communicated to our operating companies via our intranet, newsletters, onsite training, and emails.

We strive to ensure that any risks and opportunities associated with modern slavery or human trafficking are managed consistently across the whole Yesler Group and that our policies are implemented across our companies and locations and with our suppliers. We provide ongoing support to encourage and facilitate implementation of the policies by our operating entities, and regularly review the implementation of our standards to identify and address areas for improvement.

Our People

We recognise the value of human relationships and put people at the heart of our business. We seek to treat all staff fairly and consistently, to create a workplace and business environment that is open, transparent and trusted. Aligned with this approach, all members of the Yesler Group are required to conduct their activities in accordance with our codes and policies, including our Acceptable Use Policy and Anti-Harassment Policy, as they are implemented and updated from time to time.

We require our personnel to act according to the highest standards of honesty and integrity as well as comply with all legal and regulatory requirements, which extend to the protection of human rights and the prohibition of forced labour and human trafficking.

Our Supply Chains & Due Diligence

The Yesler Group expects our suppliers to treat workers and employees with respect and fairness, to have suitable anti-slavery and human trafficking policies and procedures in place, and to act and in accordance with applicable laws.

To ensure alignment between our values and ethics and those of our suppliers, the Yesler Group plans to review source locations of our procurement partners and certain direct suppliers. As a first step, we will canvass active suppliers located in the UK to assess their published commitment(s) to the prevention of modern slavery and human trafficking.

We will conduct an internal risk assessment on the Yesler Group operations by evaluating country risk in relation to office location and size, type of labor, and business operations.

As part of our procurement policy, we expect all of our suppliers to abide by the same principles and codes of conduct that we have in place. Accordingly, our suppliers must either agree to adhere to our policies and codes, or confirm their adherence to their own codes of business conduct that comprise the same principles. We will be implementing a “right to audit” clause in our standard terms or conditions to allow for oversight of compliance with these provisions.

Going forward, we plan to implement a program to include a contractual commitment to the prevention of slavery and human trafficking in renewals and new agreements with our procurement partners and direct suppliers. Further, we will review our primary procurement onboarding process with a view to including reporting on prospective suppliers’ commitment to anti-slavery and human trafficking practices.

If we find breaches of anti-human trafficking and anti-modern slavery laws within our supply chain, we will look to support businesses in their efforts to comply with such legislation. We will also actively consider how we support or conduct business with organizations involved in slavery, human trafficking, forced, or child labor.

Going forward, we will make all reasonable endeavors to ensure that any suppliers or contractors that we engage with in the provision of our services are under a contractual obligation to comply with the following mandatory policies:

  • Anti-Bribery and Corruption Policy
  • Acceptable Use Policy
  • Sustainability Policy
  • Ethical Policy
  • Equality Policy

Training & Reporting

To ensure appropriate understanding of the risks of modern slavery and human trafficking in our supply chains and within our business, the Yesler Group is committed to educating our employees, officers, and other individuals who work for us about the Modern Slavery Act 2015 and will be providing training to relevant employees (specifically those involved with the procurement of suppliers). Further, we are taking steps to reinforce with all of our personnel the available channels for reporting any suspected violations or similar concerns.

The Yesler Group has determined the following key performance indicators to measure effectiveness to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

  • A review of supply chain policies, codes of conduct, and our working practices to show commitment.
  • Ensuring we maintain a level of communication and personal contact with the next link in the supply chain to ensure their understanding of, and compliance with, our expectations.

Further Steps

The Yesler Group is committed to maintaining high ethical standards, protecting human rights, and acting with honesty and integrity in everything we do. We endeavour to understand where there are risks of modern slavery within any part of our business and supply chain so that we can address them appropriately and sustainably.

We will continue to monitor our practices and supply chains to develop and strengthen our commitment to human rights matters including the elimination of slavery and human trafficking.

This Statement is made by Yesler Group for the financial year ending 2018 and will be reviewed and published on an annual basis.

Approved by the Board

Mike Kichline
Director, CEO
Date: October 30, 2019