Slavery and Human Trafficking Statement
1. Financial year
1.1 This slavery and human trafficking statement relates to the company's financial year beginning 1 January 2020 and ending 31 December 2020.
2.1 App Annie Europe Limited (“App Annie”) is the global leader in providing mobile market estimates through it on demand SaaS platform, amongst its other products and services.
2.2 We are committed to a programme of continuous improvement in our practices to combat slavery and human trafficking in our supply chains and in our business.
2.3 This year as a group we have:
(a) consulted solicitors to assist with our approach to the issue of modern slavery and our compliance with the UK Modern Slavery Act 2015;
(b) formed an internal team to work on modern slavery issues comprising members from legal, vendor management, procurement, sales, human resources and compliance teams;
(c) developed an Anti-slavery Policy;
(d) developed a Critical Incident Response Plan;
(e) drew up an Action Plan;
(f) trained a number of key executives on the requirements of the Act;
(g) commissioned an HR audit of all personnel to ensure all have right to work documentation;
(h) developed some modern slavery clauses for our standard supplier terms and conditions;
(i) drew up a list of our first tier suppliers;
(j) carried out a desk top risk assessment of our first tier suppliers; and
(k) developed and introduced into a supplier due diligence questionnaire into procurement program.
2.4 It is our policy to conduct all business ethically and in accordance with the UK Government's Modern Slavery Strategy, as amended from time to time, and as outlined in the UK Home Office Guidance “Transparency in Supply Chains: a Practical Guide”.
2.5 We are committed to acting ethically in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter slavery and human trafficking.
2.6 We will uphold all laws relevant to countering slavery and human trafficking in all the jurisdictions in which we operate. We understand that we are covered by the UK Modern Slavery Act 2015 because:
(a) we are a body corporate;
(b) carrying on business or a part of its business in the UK;
(c) which supplies goods or services; and
(d) has a turnover of over £36 million per year.
3. Organisation's structure
3.1 We are a part of the App Annie group. App Annie Europe Limited is a wholly owned subsidiary of App Annie Limited (Hong Kong) which in turn is a wholly owned subsidiary of App Annie Inc (in the United States). App Annie Europe Limited has two subsidiaries, App Annie SAS (in France) and App Annie GmbH (in Germany).
App Annie Europe Limited provides app market, advertising analytics and data science driven insights to mobile publishers and brands. Our main suppliers are:
(a) software companies (international, mostly Europe and US);
(b) IT infrastructure suppliers (international);
(c) facilities suppliers; and
(d) ancillary administrative services (Legal, Professional consultancy etc).
4. Our business
4.1 Our business is organised to provide our services and support our customers outside of the Americas.
5. Our supply chains
5.1 Our supply chains include: Software Companies, Couriers, Catering products and services, Insurance services, food & beverages, consultancy services, audio/visual equipment services, IT equipment/software and hardware, maintenance services, professional services, recruitment services, security services, utilities, and supplies for our offices.
6. Our policies on slavery and human trafficking
6.1 We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
7. Due diligence processes for slavery and human trafficking
7.1 As part of our initiative to identify and mitigate risk we outline due diligence procedures or other relevant steps taken e.g. investigating supply chains through various tiers; speaking to suppliers; and asking them to sign up to warranties.
7.2 Our Anti-slavery Policy is a first step towards the company having in place systems to:
(a) identify and assess potential risk areas in our supply chains;
(b) mitigate the risk of slavery and human trafficking occurring in our supply chains;
(c) monitor potential risk areas in our supply chains; and
(d) protect whistleblowers.
8. Supplier adherence to our values
8.1 To ensure all those in our supply chain and contractors comply with our values and ethics we will be designing and rolling out a supply chain compliance programme.
8.2 We have a dedicated compliance team, which consists of representatives from the following departments:
(b) Audit and compliance
(c) Human resources
8.3 The team reports to Mithun Zalpuri who has overall responsibility for the company's response to the challenge of slavery and human trafficking and in accordance with the requirements of the Act has signed this statement below.
9.1 It is too early to say with any certainty how effective the steps we are taking have been and will be in ensuring that slavery and human trafficking is not taking place in our business or supply chains. As part of our work for the next financial year we will be considering how best to monitor the effectiveness of the actions taken.
10.1 To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to:
(a) Members of the App Annie Europe Limited Board of Directors
(b) Applicable members of the App Annie Europe Limited Human Resource team
(c) Members of App Annie Procurement
10.2 In the next financial year we are proposing to offer additional awareness training for App Annie Europe Limited’s employees.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. It has been approved by the board of APP ANNIE EUROPE LIMITED and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2020.
Mithun ZalpuriAPP ANNIE EUROPE LIMITED
Date: April 6, 2021