At Sage we are passionate about doing business the right way, and always staying true to two of our core company values – Do the Right Thing and Make a Difference. We are strongly committed to ensuring that our organisation is free from slavery and human trafficking and that all Sage colleagues as well as the people who work on our behalf are protected. We envision a world where all people and communities thrive because they are living with economic stability and social equality. For us, this is the right way to do business. In section 2, below, we describe how we make a positive tangible difference to the communities in which we operate.
As a software company, our business model does not carry with it a high level of slavery risk compared to businesses operating in other sectors such as manufacturing and retail. This statement therefore covers those areas within our business supply chain which we have identified as presenting a potential slavery risk. We will continue to focus on these areas until we are satisfied that we have mitigated all associated risks. In section 4, below, we describe the work we have undertaken so far to identify and act upon our supply chain risks.
Sage began as a small business in the UK 35 years ago, and over 13,000 colleagues now support millions of entrepreneurs across 25 countries as they power the global economy. We reinvent and simplify business accounting through brilliant technology, working with a thriving community of entrepreneurs, business owners, tradespeople, accountants, partners and developers. As a FTSE 100 business, we are active in supporting our local communities and invest in making a real difference through the philanthropy of the Sage Foundation https://www.sage.com/company/sage_foundation
Sage is a market leader for integrated accounting, payroll and payment systems, supporting the ambition of the world’s entrepreneurs. We create software solutions which can be delivered directly to customers, or via our network of accounting partners and distributors.
The largest part of Sage’s operations in terms of revenue generation are currently concentrated in three main countries; the United Kingdom, United States and France. A list of all the countries in which we operate can be found in our 2018 annual report here.
Sage operates a rigorous recruitment selection process for all hiring decisions which includes obtaining documented proof of the individual’s right to work in the country in which they will be employed. We will always pay colleagues at least the minimum wage rate applicable in the geography in which they work. Many companies claim that their people are their greatest asset. At Sage this is especially true, our people not only create and deliver our products but they also act as ambassadors for Sage both at work and in their communities, amongst the small businesses and entrepreneurs we serve. We therefore place great importance on investing in our colleagues’ development, and this includes providing them with the knowledge and tools they need in order for them to do business the right way. Our relationship with our colleagues starts at the hiring stage, and we aim to ensure that everyone is treated fairly and with compassion throughout their time at Sage, with all the rights and benefits that colleagues are entitled to by law enhanced by our award-winning benefit and wellbeing offerings.
All colleagues are guided by the five values which we share. These shape how we think, plan and make decisions to deliver operational excellence and best serve our customers. We are passionate about doing business the right way, and all of our colleagues are required to demonstrate the highest ethics.
Our Code of Conduct provides a clear set of rules for all colleagues and the standards of behaviour expected across all areas of our business including in relation to modern slavery concerns. The Code is overseen by the General Counsel & Company Secretary. We take compliance with our Code of Conduct extremely seriously. All colleagues are required to complete an online Code of Conduct training module when they join Sage, and on a regular basis thereafter. Members of our senior management in all parts of the business are held accountable for the compliance of their teams in completing this and all other compliance training modules. We measure training compliance on a regular basis and report on this as part of our wider risk-reporting processes to the Global Risk Committee and the Board.
We provide a confidential helpline for colleagues to raise concerns about anything they see which goes against our Code and this helpline is available 24 hours a day, 7 days a week. Calls made to the helpline are monitored by our General Counsel & Company Secretary and investigated by our Risk team. Reports on concerns raised through the hotline are made to the Board on a regular basis. The poster campaign we launched in 2017 to colleagues in all countries in which we operate was successful in raising awareness of the whistleblowing hotline scheme. The Audit & Risk Committee monitors the investigation and outcomes of all whistleblowing reports globally.
Sage has a full suite of global governance policies, which are applicable to all colleagues in all countries and which are translated into local languages where the need is identified. All global policies are reviewed and refreshed at least annually by our Policy Approval Committee which consists of our CFO, Chief People Officer, General Counsel & Company Secretary, and VP Risk and Assurance, to ensure that they accurately reflect current legislation and best practice. There is a policy governance framework in place to administer the review process and operationalise any policy changes across the relevant business processes and procedures. Regular training and awareness activities form a core part of our programme to embed Sage policies across all parts of our business. All policies are accessible to colleagues 24/7 via Sage’s intranet.
At Sage, one of the many ways in which our colleagues can live the Sage values is through volunteering with Sage Foundation. Sage Foundation’s mission is to create routes into education, work and entrepreneurship for young people, women and military veterans. During FY18, Sage colleagues volunteered 24,000 working days supporting Sage Foundation. Whilst the activities of Sage Foundation do not directly address modern slavery, by empowering these vulnerable groups and providing work and education opportunities we can help towards creating an environment in which slavery risks are reduced.
In FY18, we spent £470m with third parties in IT, marketing, real estate and facilities and professional services (excluding rent and business rates). 52% of this spend took place in the UK and USA. All of our spend commitments are made using written contracts and we do not pay cash for services. Our major suppliers are large multinational companies who have their own ethical standards of behaviour in place. Cushman & Wakefield, a global property consultancy firm, have provided all of our facilities management services including building security where Sage is the only building occupant and cleaning, since 2016. Our contract with them specifies that they must comply with the Modern Slavery Act 2015 (MSA). We believe that this arrangement mitigates in great part the most significant slavery and human trafficking risks identified in our supply chain.
Given the nature of Sage’s business model, we believe the risk of modern slavery in our supply chain is low compared to businesses operating in other sectors such as manufacturing and retail. We have not identified any instances of modern slavery occurring in our supply chain and therefore it can be difficult to measure the effectiveness of our policies in reducing the risk of slavery and human trafficking. However, we recognize that there is not room for complacency and will continue to work to enhance our policies and procedures and measure awareness within our business.
Our Supplier Code of Conduct, which was launched in 2017 and can be found here, sets out clearly our expectations and the standards of behaviour we expect from all our suppliers across a range of issues and specifically addresses fair treatment of their employees and slavery and human trafficking in their own supply chains. The Code has been translated into six languages and is implemented by our Procurement team led by the EVP Property & Procurement who reports into our CEO. The Code also sets out clearly how suppliers can raise concerns to us, with escalation up to the EVP Property & Procurement and the General Counsel & Company Secretary. Suppliers can also report concerns using our independent, confidential whistleblowing hotline, with any incoming reports reviewed by the General Counsel & Company Secretary, investigated by the Risk team and reported to the Board. All new suppliers must now agree to sign up to our Supplier Code of Conduct, giving us comfort that they understand the importance we place on these issues right from the start of our relationship with them.
Our standard form procurement contracts now include language requiring suppliers to comply with anti-slavery and human trafficking legislation, including the MSA where applicable, and we continue to roll these out more broadly across the business where existing contracts come up for renewal. Last year we reported the implementation of our own enterprise management solution Sage Enterprise Management in 5 countries. In 2018 we added a further 9 countries, bringing the total to 14. Implementing a single purchase and invoicing system in this way gives us assurance that all of our lower value procurement activity is being approved in accordance with our procurement policies and delegation of authority procedures. For higher value contracts, our procurement sign-off process includes a due diligence check to ensure that negotiated contracts include a requirement for suppliers and their sub-contractors to adhere to our Supplier Code of Conduct.
We have recently started to capture data on the number of contracts which contain our agreed anti-slavery wording. This exercise showed that 28.82% of contracts reviewed contained this wording. Upon further examination, it became apparent that the categorisation of contracts allowed for only a yes/no response. This meant that whilst some contracts were categorized as “no” because they did not contain anti-slavery wording, others were being captured which either had = bespoke anti-slavery wording or some other commitment, or which did not require anti-slavery wording because they are for the provision of non-applicable services such as individual consultancy. In order to have a clearer understanding of our suppliers’ commitments to anti-slavery measures, we are currently considering how best to capture and report on this data going forward.
We have taken the following steps to improve awareness around issues around slavery and human trafficking this year and to measure the effectiveness of our policies and procedures. All of these actions are intended to take effect across all countries in which our business operates, but have been rolled out in stages, and so are more firmly embedded in some countries than others.
There were no instances of slavery or human trafficking concerns raised to us during the financial year under review.
During the remainder of FY19, we shall be continuing the roll-out of Sage Enterprise Management to additional countries and review and enhance the metrics we use to measure the effectiveness of the actions we have taken so far with respect to our policies and procedures. Having gathered data on the number of supplier contracts which include our new standard terms, we are reviewing a breakdown of those contracts identified as not including our preferred contract clauses and review these on a risk-assessed basis. We shall continue to focus on activities which embed our current policies, processes and procedures (including contract due diligence) more effectively in those countries we identify as requiring greater support to reach the expected standard. We shall monitor the implementation of modern slavery legislation in other countries in which we operate, such as Australia, and seek to meet our reporting obligations globally in a simple, consistent and transparent manner. We have updated this statement prior to the usual annual review date to ensure that in future it contains the most up to date information as shown in our most recent annual report, published in December each year. In our next update, we plan to show more detailed information on the types of workforce employed in each county in which we operate and our supplier spend by category.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Sage Group plc’s updated slavery and human trafficking statement for the financial year ending 30 September 2018 and has been approved by the Board of The Sage Group plc. It is made on behalf of all subsidiaries within the Group who may be required to make a statement pursuant to the Modern Slavery Act 2015*.
The Sage Group plc
Date: 27 February 2019
*These subsidiaries are as follows:
Sage (UK) Ltd - a company incorporated in the UK.
|27 February 2019
||2019 Anti-Slavery and Human Trafficking Statement|
|30 September 2018||2018 Anti-Slavery and Human Trafficking Statement|
|30 September 2017||2017 Anti-Slavery and Human Trafficking Statement|
|30 September 2016||2016 Anti-Slavery and Human Trafficking Statement|