Legal

OpenX Modern Slavery Act Statement

for the Financial Year ending December 31, 2018

Introduction

OpenX is committed to understanding potential modern slavery risks related to our business and ensuring that there is no modern slavery in our own business and supply chains.  We endorse the principles of the Modern Slavery Act 2015 and we do not condone modern slavery in any form.  This statement covers the financial year, January 1, 2018 to December 31, 2018.

 

Structure and Supply Chains

OpenX Software Limited and its affiliates (“OpenX”) operate the world’s largest independent digital advertising exchange connecting top brands with consumers across the most trafficked websites and mobile apps globally.  We currently have offices in the United Kingdom, the United States, Germany, Poland and Japan. We have contracts in place with publishers and application developers which provide digital advertising inventory, and demand partners who purchase digital advertising inventory via our digital advertising exchange. We also purchase professional services, IT equipment and office materials, among other things, from third party suppliers.     

 

Policies on Modern Slavery

 

We are dedicated to ensuring that human rights are respected at all times. Our code of conduct requires employees to maintain the highest ethical standards and comply with all applicable laws and company policies. We strive to maintain the highest standards of employee conduct and ethical behavior when operating abroad and managing our supply chain.

 

We encourage our team members to report any suspected wrongdoing or dangers in relation to any activity that falls short of our code of conduct.  This includes any circumstances that may give rise to an enhanced risk of slavery. By encouraging a culture of openness and accountability within OpenX, we believe that we can help prevent illegal or unethical practices from occurring.  Our procedure is designed to make it easy for our team members to make disclosures without fear of retaliation.

 

Due diligence processes

 

OpenX undertakes due diligence when considering taking on new partners and suppliers.  We expect all our contractors, suppliers and other business partners to adopt the same high standard as we do to prevent modern slavery, by ensuring their operations are conducted with dignity and respect in a fair and ethical environment.

Risk Assessment

 

Considering our digital advertising business consists of predominantly professionally qualified and highly skilled people and the lengths of our supply chains are relatively short, we assess the risk of modern slavery within our business and supply chain to be low.  However, we are committed to preventing slavery in all of our corporate activities, and to ensuring that our supply chains are free from slavery including servitude and forced or compulsory labour.  

 

Training for staff

 

We recognize the importance of training in combating modern slavery.  In 2019 we plan to conduct anti-slavery training for relevant internal stakeholders including but not limited to our legal team.  The training will help staff better recognize the risks of modern slavery in our business and supply chains.

 

Measuring Effectiveness

 

We will measure our effectiveness the following ways: (a) periodically reviewing our relevant policies and updating them as necessary; (b) confirming that employees have acknowledged our code of conduct; and (c) conducting anti-slavery training for relevant staff in 2019.  

 

Board Approval

 

This statement has been approved by our board of directors on December 4, 2018.


OX19 DM Sig - Modern Slavery Act Statement

Douglas McPherson

Secretary

January 14, 2019