Financial year 2018
Modern Slavery Statement
Financial year 2018
Modern Slavery Statement
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that the BASEBONE Group (hereinafter referred to as “BASEBONE”. “Basebone Group” means Basebone Group Ltd and its related trading companies) has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. BASEBONE has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
BASEBONE operates Mobile Entertainment services across South Africa, Kenya, Nigeria, United Kingdom, Belgium, France and the MENA Countries via a number of 100% controlled trading entities as well as Mobile Aggregation Services across South Africa, Kenya and Nigeria via its subsidiaries, those being respectively: a) Basebone PTY Limited; b) Basebone Kenya Limited; and c) Basebone Services Nigeria Ltd.
Moreover, in 2018, BASEBONE has added a new company to the Group, Baseplay Ltd., which has created our brand-new product “Baseplay”, an interactive platform on which our customers can enjoy a multitude of high-quality mobile entertainment contents. Further information on our business, our products and how we build and protect value is available on the company website (www.basebone.com).
BASEBONE headquarters are in London and our significant operational hubs are across South Africa (Cape Town and Johannesburg), Kenya (Nairobi), Nigeria (Lagos) and Spain (Marbella and Málaga). In 2018, we worked with 1100 first-tier suppliers headquartered around the world.
Due to our size and the relevance of our geographic reach, ensuring we avoid any involvement in modern slavery, particularly beyond our first-tier supplier, is a discernible challenge. Nonetheless, we are fully committed to improve the way we work with Regulatory bodies, Business Partners and our Customers to meet our moral and ethical obligation to fight modern slavery and to ensure it does not occur in connection with our business and supply chain.
2019 Projects – Areas of Focus
2019 represents a big challenge for our company in terms of identifying potential Modern Slavery risk areas.
The plan of action has already been developed and the main actions we will take can be summarised under the following points:
- Investment in innovation of our “Supplier management system” in order to have a deeper understanding of the modern slavery risks for our first-tier suppliers;
- Investment in training for our employees to better understand the implications of our footprint and relevant modern slavery risks and indicators;
- Creation and implementation of a Supply Chain Assurance Program.
Risk identification and management
All Basebone employees are aware that when making a decision and/or taking an action, they are implicitly assuming a risk. This is why, at Basebone, we are constantly monitoring our risk exposure to ensure that we have the necessary controls in place and that we are doing our utmost to minimise if not eliminate this risk. We provide our employees with the tools they might need in order to discover, understand and react to such risks in the most efficient and compliant way.
In order to ensure the efficiency of our Modern Slavery risk detection approach in our supply chain, we have decided to structure the same based on various factors, such as:
- The nature of our relationship with our suppliers;
- The suppliers’ geographic location and the relevant applicable human rights legislation; and
- The kind of service they are providing us with.
Our choice to use such an analytic approach has allowed us to improve our understanding of localised human right risks and to better identify where those risks may intersect with our supply chain.
Modern Slavery cannot be considered as a stand-alone crime; therefore, the Supply Chain crosschecks we have implemented encompass the risks associated with a broader range of factors, such as:
- Crimes of Human Trafficking;
- Slavery like practices;
- Forced Labour;
- The sale or exploitation of children;
- The debt bonded labour;
- Workplace health and safety;
- Cyber security;
- Bribery and Corruption.
Moreover, the Supply Chain Crosscheck activity is closely mapped by our internal Risk Management function, which is constantly assessing all the risks associated with our business and operations. This recurrent risk assessment activity provides the Company with an on-going “Group Risk Profile” and ensures prioritisation of internal and external facing activities to control/minimise the level of risk while continuously improving the internal crosschecks’ system.
In order to better understand the Company actual Modern Slavery risk exposure, please find below a graph showing the proportion of people estimated to be enslaved according to their region as reported by the Global Slavery Index 2018. For comparative purposes, the second graph shows Basebone’s first-tier suppliers by region:
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
- Modern Slavery Statement. This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.
- Recruitment policy. We operate a robust recruitment policy, including conducting eligibility checks for employment, in each of the countries in which we operate.
- Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about our practices within our business or supply chain, including how colleagues are being treated, without fear of reprisals. Using different technologies, employees are able to report grievances or any other issue anonymously to Management, who will take every possible step to protect their identity. All reports relevant to any breach of policy, law or other rules are taken very seriously and are assessed and investigated accordingly.
- Basebone Code of Conduct. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.
- Global Policy Manual. This Policy manual sets out Basebone’s commitment to good business practice and ethics to which the company expects all employees to adhere to.
- Basebone Spirit. This document sets the behavioural standard based on which we operate inside and outside the business when representing Basebone.
- Partner Standards. This document provide detailed information on how we expect our partners to conduct their business when interacting with Basebone and puts special emphasis on the Anti Bribery standards that we apply and that we expect to be applied by our suppliers.
Suppliers Due Diligence Process
Basebone operates a first-tier suppliers policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search, using emerging technologies, as well as reputational assessments to ensure that particular organisation has never been convicted of offenses relating to modern slavery and, if viable, on site audits which include a review of working conditions. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradict this policy.
In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:
- They have taken steps to eradicate modern slavery within their business;
- They hold their own suppliers to account over modern slavery;
- For UK based suppliers, that they pay their employees at least the national minimum wage/national living wage (as appropriate)
- For international suppliers, that they pay their employees any prevailing minimum wage applicable within their country of operations
- Should any instances of modern slavery come to light, this would constitute a serious breach of contract and we would be able to terminate the contract immediately.
Although our supplier due diligence procedure currently relies heavily on desktop audits, we nevertheless recognise that onsite audits would provide a better result in detecting modern slavery behaviours, which are illegal and largely hidden, often making it extremely difficult to detect.
However, undertaking onsite audits for each and every one of our suppliers is not practical and would be very costly as well as inefficient from a time perspective. Therefore, in 2019 the Company has will implement an “Advanced Due Diligence Program” for suppliers that present an elevated risk to the Group. Once the Advanced Due Diligence Program is complete, where relevant and viable, Basebone will introduce a corrective plan and the supplier will enter into a monitoring program. Where the corrective plan is not viable, Basebone will immediately terminate any contractual relation with the supplier.
As we are working towards best practice, we aim to test the effectiveness of the Program by building capability and awareness of the main Modern Slavery indicators, implied risks and social impact both within Basebone and our suppliers.
Since 2015 to date, our due diligence procedures have not identified any supplier with instances of non-conformance regarding the Modern Slavery risk, and, therefore, no corrective actions have been necessary.
We regularly conduct training for each and every of our teams members so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain. In 2018 we have focuses on building awareness amongst procurement professionals and business unit leaders, by providing them with training resources. Going forward the “Advanced Due Diligence Program” will expand the training activities to include broader groups of Basebone employees and suppliers.
Sustainability and Short/Medium Term Priorities
During 10 years of operations, Basebone has experienced significant changes. We have responded by transforming and adapting our business by setting clear milestones to reach our goals in terms of supporting the global mobile entertainment community. The idea now is to replicate this approach in the way we manage human rights within our organisation.
We define sustainability in simple terms and this includes our approach to human rights and social impact. We continuously monitor the global forces that can affect our growth and future success and hold ourselves accountable by giving others the chance to evaluate our performance based on publicly available information.
These global forces, together with stakeholder dialogue and collaboration, allow us to identify the main salient human rights issues and set our strategic priorities to mitigate risk and maximise opportunities over the short, medium and long-term.
Short Term Priorities
In order to efficiently tackle the Modern Slavery issue, the immediate actions Basebone will take are:
- Complete the Modern Slavery Awareness Training program across all legal, sales and human resources functions as well as for procurement professionals;
- Create a comprehensive report of salient human rights potential issues across the Group and communicate the same in the 2019 annual General Strategy Meeting;
- Successfully launch the “Advanced Due Diligence Program” regarding suppliers and provide the relevant reporting of the number and nature of detected potential risks;
- Update the Basebone set of policies to include the Group’s commitment to human rights by incorporating in each of them our position on Modern Slavery risks, due diligence and remedial actions.
Medium Term Priorities
Once implemented the short-term action plan, Basebone will focus on the medium-term needs of the Modern Slavery prevention and remediation strategy and will implement the following measures:
- Launch an industry wide collaboration program, involving the relevant Regulatory Bodies and Industry Partners, in order to detect and prevent Modern Slavery in Mobile Entertainment and VAS Services across the different countries the Company operates in;
- Analyse the results of the first-tier suppliers chain risk-based crosschecks and, where possible, replicate the structure extending the same to second-tier suppliers;
- Review the “Advanced Due Diligence Program” procedures to ensure it is fit for purpose and addresses key salient human rights risks;
- Review the Modern Slavery Awareness Training program and, if needed, roll out a tailored version of the same to employees whose responsibilities are more likely to be exposed to human rights risks.
Approval for this statement
The Board of Directors approved this statement on the 15th December 2018
Name: Michael Holmqvist
Title: Basebone Group CEO