Conversant Europe Ltd. Modern Slavery Transparency Statement

This statement is made pursuant to the requirements of the UK Modern Slavery Act of 2015 and covers Conversant Europe’s UK-based entity, Conversant Europe Ltd., along with its subsidiaries (collectively “Conversant Europe”).

Conversant Europe takes its responsibilities very seriously. We continuously strive to work to the highest professional standards and comply with all laws, regulations, and rules relevant to our business. We expect the same high standards from those businesses with which we work. Consequently, we are committed to implementing and enforcing effective systems and controls to ensure that slavery and human trafficking are not taking place anywhere in our business or supply chains.

About the businesses

Conversant Europe Ltd. is a wholly-owned subsidiary of Alliance Data Systems Corporation (NYSE: ADS) (“Alliance Data”). Alliance Data is a leading global provider of data-driven marketing and loyalty solutions serving large, consumer-based businesses in a variety of industries. Alliance Data offers a comprehensive portfolio of integrated outsourced marketing solutions, including customer loyalty programs, databased marketing services, end-to-end marketing services, analytics and creative services, direct marketing services, and private label and cobrand retail credit card programs. Alliance Data helps its clients create and increase customer loyalty through solutions that engage millions of customers each day across multiple touch points using traditional, digital, and mobile and emerging technologies.

An S&P 500 and Fortune 500 company headquartered in Plano, Texas, Alliance Data, through its wholly-owned subsidiaries, employs more than 17,000 associates at approximately 100 locations worldwide.

Alliance Data maintains various policies and practices that demonstrate its commitment to conducting business in an ethical and transparent manner.

Code of Ethics - Ethics and integrity are fundamental to how Alliance Data conducts its business.  Alliance Data’s Code of Ethics addresses its commitment to comply with laws and regulations and to conduct business with the utmost integrity.  The Code of Ethics provides guidelines on how its associates should conduct themselves at work and with each other and demonstrates commitment to its stockholders, customers and business partners.   

Supplier Code of Conduct – Alliance Data’s Supplier Code of Conduct helps to ensure that its suppliers conduct business with integrity and in a lawful and ethical manner.  This Supplier Code of Conduct addresses Alliance Data’s key values and provides guidelines on how it should interact with its suppliers, as well as what it expects from its suppliers. 

Recruitment Alliance Data’s recruitment process includes conducting checks confirming an individual’s eligibility to work in the UK and other countries in which it operates to safeguard against human trafficking or individuals being forced to work against their will.

Conversant Europe’s supply chain

Due to the nature of its business, Conversant Europe’s supply chain is limited and low risk. It does not sell or produce physical goods as part of its business. The supply chains include suppliers of goods and services in the following areas: operations and infrastructure support, recruitment and training, IT services, and office services.

The direct suppliers to the Company are primarily based in the United Kingdom, the European Union or the United States. Our subsidiaries in China, Hong Kong and South Africa use a small number of suppliers for local requirements from their respective countries. Whilst we do not consider our supply chain to be high risk, we have used a supplier risk management process for a number of years to assess our suppliers.

Conversant Europe’s approach to tackling modern slavery

Conversant Europe is committed to implementing and enforcing effective systems and controls to ensure that slavery and human trafficking are not taking place anywhere in the business or in its supply chains. It is not, nor has it ever been, aware of any actual or suspected slavery or human trafficking within its own business or the businesses of its suppliers.

To achieve our commitment to tackling modern slavery, we have taken or are taking the following steps:

We have developed and implemented a robust supplier review process to better assess the geographical and business and operational risks of our suppliers.

Introduction of an internal Modern Slavery Policy (“Internal Policy”) that will be made available to associates to whom such Internal Policy applies and will be updated as necessary.

The Internal Policy includes, amongst other things: (i) our zero-tolerance approach to modern slavery; (ii) the need to comply with the policy and the procedure for reporting any concerns; (iii) the training that will be made available; and (iv) the consequences of a breach of the policy.

Preparation of contractual provisions relating to modern slavery for Conversant Europe’s suppliers.

These additional provisions include: (i) a requirement that the supplier and its subcontractors comply with all applicable anti-slavery laws, including the Modern Slavery Act; (ii) warranties that the supplier is not aware of any circumstances in their supply chain that could give rise to any offence in connection with slavery and human trafficking; (iii) an obligation to notify Conversant Europe if they become aware of any actual or suspected slavery or human trafficking; and (iv) an obligation to provide us with their own slavery and human trafficking report upon request.

Introduction of a Modern Slavery Policy for Suppliers (“Supplier Policy”)

All of our suppliers and their subcontractors will be contractually required to acknowledge their awareness of the Supplier Policy, which emphasises our commitment to ensuring that slavery and human trafficking are not taking place in our supply chains. The Supplier Policy also encourages suppliers to notify us of any concerns they may have about modern slavery in any part of our business or supply chain.

Implementation of a training scheme.

We have implemented ongoing training on modern slavery for associates working for, on behalf of, or with Conversant Europe.

We continue to review our policies and processes in an effort to ensure the highest standards in our business and our supply chains.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our transparency in supply chain statement for the financial year ending on December 31, 2017.

On behalf of Conversant Europe Ltd.