RELX PLC PROTECTING HUMAN RIGHTS
M O D E R N S L A V E R Y A C T S T A T E M E N T
This statement, approved by the RELX Board on 13 February 2024, has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by RELX PLC and its subsidiaries to prevent modern slavery and human trafficking in its business and supply chain during the year ending 31 December 2023 [1]. This is our eighth Modern Slavery Act statement. Past statements can be found here.
OUR COMPANY
RELX is a global provider of information- based analytics and decision tools for professional and business customers, enabling them to make better decisions, get better results and be more productive.
Our purpose is to benefit society by developing products that help researchers advance scientific knowledge; doctors and nurses improve the lives of patients; lawyers promote the rule of law and achieve justice and fair results for their clients; businesses and governments prevent fraud; consumers access financial services and get fair prices on insurance; and customers learn about markets, source products and complete transactions.
Our purpose guides our actions beyond the products that we develop. It defines us as a company. Every day across RELX our employees are inspired to undertake initiatives that make unique contributions to society and the communities in which we operate.
RELX has:
36,500+
Over 36,500 employees worldwide
40+
Countries with offices
6
Based in six continents
180+
Serving customers in 180+ countries worldwide
We operate in four major market segments,
Risk, Scientific, Medical & Technical, Legal and Exhibitions. In 2023, electronic products and services accounted for 83% of revenue, up from 30% in 2003.
Risk combines data and analytics with deep industry expertise to help customers make better decisions and manage risk. We help detect and prevent online fraud and money laundering and deliver insight to insurance companies. We provide digital tools that help industries from aviation to banking improve their operations. Risk comprises the following market-facing industry/sector groups: Business Services, Insurance Solutions, Specialised Industry Data Services and Government Solutions. Key products include Cirium, powering data and analytics needs of the majority of the world's airline groups, airports, aircraft finance, manufacturers, tech giants and travel companies; and ICIS, which has been providing pricing data and insights on the recycled plastics market for over 15 years, helping customers further a sustainable future in the transition to a circular economy.
Scientific, Technical & Medical helps researchers and healthcare professionals advance science and improve health outcomes by combining quality information and data sets with analytical tools to facilitate insights and critical decision-making.Elsevier's services across Academic and Government, Corporate and Health segments focus on: Databases & Tools including e- reference content: Primary Research; and Print products. Significant key products include: Science- Direct, the world's largest platform dedicated to peer-reviewedprimary scientific and medical research; Scopus and SciVal, which offers insights to support decision- making; and ClinicalKey, the flagship clinical reference platform accessed at over 5,000 institutions in over 80 countries.
Legal provides legal, regulatory and business information and analytics that helps customers increase their productivity, improve decision- making and achieve better outcomes. LexisNexis hosts over 138bn legal and news documents and records. On average,
2.2m new legal documents are added daily from 50,000 sources, generating 158bn connections. Nexis news and business content includes over 39,000 premium sources in 50 languages, covering more than 180 countries. Legal analytics tool, Lex Machina, has normalised over 172m counsel mentions and over 134m party mentions since 2016.
Exhibitions (RX) organises influential events in key markets focused on addressing the needs of each particular industry. It combines industry expertise with data and digital tools to help customers connect face-to-face and digitally, learn about markets, source products and complete transactions. In 2023, RX ran 286 face-to-face events in 25 countries and over 6m participants welcomed the opportunity to build their businesses at RX events.
We focus on our unique contributions
as a business where we make a positive impact on society through our knowledge, resources and skills, including:
Universal, sustainable access to information
Advance of science and health
Protection of society
Promotion of the rule of law & access to justice
Fostering communities
Detailed information about the segments, each of their business models and our unique contributions can be found in the RELX Annual Report on relx.com.
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OUR COMMITMENT TO PROTECT HUMAN RIGHTS
Modern slavery is the exploitation of another person for commercial or personal gain. It is an umbrella term for human trafficking, sexual exploitation, domestic servitude, forced and bonded labour.
The ILO Report from 2022 defines modern slavery as "situations of exploitation that a person cannot refuse or cannot leave because of threats, violence, abuse of power or coercion."
We stand against all forms of slavery and human trafficking. We do not tolerate it in any part of our business, including our supply chain. We are a signatory to the United Nations Global Compact (UNGC) Ten Principles related to human rights, fair and non-discriminatory labour practices, the environment, and anti-corruption. Our policies are also informed by the Universal Declaration of Human Rights, the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the Women's Empowerment Principles. We have consulted widely on a RELX Human Rights Policy which we will launch in 2024.
We are aware of the risk of modern slavery given our global presence and diverse supply chain. We have robust human rights due diligence processes in place which include:
Assessing risks in our own operations and our supply chain through consultations with key stakeholders and through the use of due diligence tools
Providing training to teams who are more likely to face potential modern slavery issues Conducting awareness raising campaigns for all employees, including materials for all employees on detecting modern slavery
Enhancing our policies when necessary to address modern slavery risks
Prioritising key risk areas so that steps can be taken to monitor them more closely and provide remediation if necessary
At RELX, all employees have an obligation to conduct business with integrity including respecting human rights.
We have a governance structure in place to support
this very important objective, including personnel devoted to corporate responsibility, procurement, audit, compliance, corporate affairs, and legal.
The CEO is responsible to the Board for the ethical operation of our business, including respecting human rights, supported by the CEOs of our business areas, the Head of Corporate Affairs, the Chief Legal Officer, the Chief Financial Officer, the Chief Sustainability Officer, the Chief Compliance Officer, the Chief Procurement Officer, the Chief Human Resources Officer and colleagues throughout our company.
OUR PEOPLE
As a global provider of information-based analytics and decision tools for professional and business customers, RELX attracts and develops highly skilled professionals who can realise their career aspirations. Given the nature of our work and workforce, the risk is low for human trafficking and modern slavery in our direct operations.
We employ over 36,500 people in more than 40 countries worldwide. Approximately 69% of our employees are based in North America and Europe. The Philippines is our third largest geography where 14% of our employees are located.
We have over 1,300 contingent workers through our central programme for contingent labour who provide support such as editorial, technical, project management, and administrative services. Contingent workers engaged through our central programme, their providers are subject to our Supplier Code of Conduct.
OUR SUPPLY CHAIN
RELX has a diverse supply chain with suppliers located in over 150 countries. These suppliers are spread across multiple categories including technology (e.g. software, cloud, hardware, and telecom), indirect (e.g. consulting, marketing, contingent labour and travel), and direct (e.g. data/content and production services, print/paper/bind, distribution). Our top ten supplier countries are Australia, Canada, China, France, Germany, India, Netherlands, Philippines, UK and US.
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RELX supplier locations (% of supplier spend)
North America | Europe |
28.8% | |
59.9% |
Middle | Asia & |
East | |
1% | Pacific |
9.1% | |
Africa
0.5%
South
America
0.7%
Based on four quarters ending Q3 2023
POLICIES TO AVOID SLAVERY AND HUMAN TRAFFICKING
OUR BUSINESS
Our Code of Ethics and Business Conduct (Code) sets the standard for our corporate and individual behaviour. The Code, available to every employee, is acknowledged by employees during training, and is publicly available at www.relx.com. Our Code of Ethics and Business Conduct supports the principles of the United Nations Global Compact (UNGC) and stresses our commitment to human rights and supporting fair and non-discriminatorylabour practices, among other provisions. In accordance with the UN's Guiding Principles on Business and Human Rights, we consider where and how we operate to avoid human trafficking and modern slavery in our direct operations and in our supply chain. The Code, on page 41, clearly states that we "support and respect international human rights" and work to "ensure that we are not complicit in human rights abuses."
The Code is available in 13 languages to ensure all our employees understand it. It is supplemented by other policies to further assist employees in complying with laws related to anti- bribery, competing fairly, data privacy and
security, trade sanctions and preventing workplace harassment.
Employees receive mandatory training on the Code - both as new hires and at regular intervals during their tenure - in order to maintain a respectful workplace, prevent bribery and protect personal and company data.
Mandatory periodic training covers key Code topics in depth and is supplemented by advanced in-person training for higher-risk roles. We ensure training effectiveness by tracking completion rates and feedback during and after training.
We are committed to an inclusive workplace, with diversity that reflects our customers and communities, and a culture that welcomes individuals and their contributions, regardless of gender, race or other characteristics protected by law, as stated in ourInclusion and Diversity Policy. We have publicly stated inclusion goals to ensure diverse representation across our business.
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We are an equal opportunity employer. We are committed to treating all employees and applicants for employment with respect and dignity, and we prohibit discrimination. We recruit, hire, develop, promote, and provide conditions of employment without regard to any diversity characteristics protected by law.
We understand skill-level can be an indication of risk and that some countries are at higher risk for human rights issues which is why, when prioritising focus areas for avoiding human trafficking and modern slavery, we consider location, type of work and employment status.
CONFIDENTIAL REPORTING & EMPLOYEE SUPPORT
We maintain compliance committees for each RELX market segment. Employees are expected to report suspected violations of the Code or law to a manager, a human resources representative, a company lawyer or the appropriate compliance committee. We also offer employees a confidential reporting line, the Integrity Line, managed by an independent third party, which is accessible by telephone or online 24 hours a day, 365 days a year. As allowed under applicable law, employees may submit reports to the Integrity Line anonymously.
Reports of violations of the Code or related policies are promptly investigated, with careful tracking and monitoring of violations and related mitigation and remediation efforts. The Code provides retaliation protection for those reporting suspected violations and those who assist in providing information in response to a report. For more information about RELX reports of alleged violations of the Code visit https://www.relx.com/investors/corporate-governance/code-of-ethics
Substantiated Code breaches are subject to disciplinary action, up to and including termination of employment. The Integrity Line also includes "Ask a Question" functionality which provides another avenue for employees to get ethics and compliance advice before taking action.
RELX tracks alleged violations from its reporting channels and enquiries received through the Integrity Line. We analyse violations and reports by subject matter, business line, and geography, among other categories and report trends and mitigation efforts to senior management and the Audit Committee of the Board.
We use a UK government definition of modern slavery, particularly "the trafficking of people, forced labour, servitude and slavery." We did not receive any reports or questions from employees that related to modern slavery during the reporting period.
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OUR SUPPLY CHAIN
We have a comprehensive Supplier Code of Conduct (Supplier Code), available in 16 languages, which we ask suppliers to adhere to and display prominently in the workplace. It commits them to following applicable laws and best practice in areas such as human rights, labour and the environment.
It also asks our suppliers to require the same standards in their supply chains, including requesting subcontractors to enter into a commitment to uphold the Supplier Code. The Supplier Code states that, where local industry standards are higher than applicable legal requirements, we expect suppliers to meet the higher standards. Our Socially Responsible Supplier (SRS) programme is a key aspect of our work to prevent modern slavery and human trafficking in our supply chain.
The Supplier Code contains provisions on child labour, involuntary labour, wages, coercion and harassment, non-discrimination, association, health and safety, environment and anti- corruption. In accordance with the UK's Modern Slavery Act 2015 and based on the American Bar Association's Model Business Conduct Standards to Eradicate Labor Human Rights Impacts in Hiring and Supply Chain Practices, our Supplier Code specifically prohibits participation in any activity related to human trafficking.
Our Supplier Code states unequivocally that suppliers cannot directly or indirectly use, participate in, or benefit from involuntary workers, including human trafficking or related activities. To strengthen adherence to our Supplier Code, we embed it into standard terms and conditions (such as contracts and purchase orders).
We continue to work with non-signatories to gain agreement to our Code, and/or assess whether they have equivalent standards in place, in order to ultimately decide whether to continue doing business with them.
EXCERPT FROM SUPPLIER CODE ON INVOLUNTARY LABOUR
"Suppliers will not directly or indirectly use, participate in, or benefit from involuntary workers, including human trafficking related activities, for example:
- using misleading or fraudulent recruitment or engagement practices for employees or contract workers (ii) charging employees and/or contract workers recruitment or engagement fees;
- destroying, concealing, confiscating, or otherwise denying access by an employee or any contract worker to his or her identity documents, such as passports or drivers' licenses); or (iv) using workers who are imprisoned, indentured, bonded, military or slaves."
TOP 10 SUPPLIER COUNTRIES
Australia
Canada
China
France
Germany
India
Netherlands
Philippines
UK
US
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DUE DILIGENCE
OUR BUSINESS
We are committed to assessing our global employee workforce to ensure we adhere to our commitment to fair pay. A living wage is determined by the average costs to live, rather than the minimum wage which is lower and determined by law. To date we have assessed nearly half of our employees in our global operations, and all are paid a living wage.
We are a living wage employer in the UK, accredited by The Living Wage Foundation. This means our employees and contractors are paid a living wage. We monitor living wage rates as they increase to identify any necessary adjustment in wages to ensure alignment. We have an alert in our HR system to notify reward managers if a UK employee's wage falls below this threshold, which is then adjusted.
We continue working with our partners at BSR to access living wage data and work to align methodologies as we undertake assessments with accrediting bodies, Living Wage for US in the United States and the Global Living Wage Affiliate Network, which provides support for multinational employers.
We are committed to paying people equitably and fairly and continue to monitor job architecture to improve consistencies in pay. Our robust job architecture system within our HR platform, Workday, supports this aim.
RELX Reward provides training on pay equity principles with leaders across the business. The training focuses on our pay equity strategy and the tools and controls in place to ensure pay equity in both the near and long-term.
RELX participated in the CCLA Modern Slavery UK Benchmark 2023, developed in support of Find it, Fix it, Prevent it a collaborative investor initiative on modern slavery. The benchmark assesses the largest UK companies on the steps they are taking to eradicate modern slavery in their operations and supply chains. RELX was
rated as "Evolving good practice," showing evidence of human rights due diligence practices on modern slavery informed by experts and/ or civil society partners; and evidence of activity in the find it, fix it, and prevent it categories.
We also scored 100% in the Human Rights Campaign Foundation's 2023 Corporate Equality Index, the national US benchmarking tool on LGBTQ+ corporate policies, practices and benefits on workplace equality.
OUR SUPPLY CHAIN
Given the importance of an ethical supply chain, we maintain a Socially Responsible Supplier (SRS) programme encompassing all our business areas, supported by colleagues with expertise in operations and procurement and a dedicated SRS Director from our global procurement function.
We use a country risk ranking tool to determine risk in our supply chain. The tool, developed by a third party, incorporates eleven indicators including data from the ITUC Global Rights Index, the US State Department Trafficking in Persons report, the Human Development Index, the Freedom in the World Civil Rights survey, the Rule of Law Index produced by the World Justice Project and UNICEF's percentage of children aged 5-14 years engaged in child labour data, to determine the risk level of each country. 80% of our global spend was subjected to risk assessment in 2023.
In addition, we monitor our supply chain by using our own tools (LexisNexis Entity Insight and Bridger Insight XG) and other commercially available tools.
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Location of supplier's audits
Europe | ||||
North America | 23% | Asia & | ||
44% | Pacific | |||
29% | ||||
South
America
1%
Australia
3%
We track suppliers with whom we spend more than $1m annually; suppliers identified as critical by the company; and those located in medium- and high-risk countries (as designated by our third-party developed supplier risk tool) with a spend of $100,000 or more per year for the most recent consecutive two- year period.
The tracking list changes year-on-year based on the suppliers we engage to meet the needs of our business and/or changes in country risk designations within our third-party risk tool. In 2023, there were 796 suppliers on the SRS tracking list, 66 of which were in high-risk countries and 606 in medium risk countries.
690 of the suppliers (87%) on the tracking list have signed our Supplier Code, or have equivalent standards in place.
The majority of the non-signatories are new to the SRS tracking list and we are working with them, and other non-signatories, to gain agreement of our Code. In total, at the end of 2023 there were 5,322 signatories to our Supplier Code, or have an equivalent code, representing an increase of 19% from the 4,467 signatories in 2022.
MONITORING SUPPLIERS
Where required by law, suppliers must have employment contracts signed with all employees in the applicable local language clearly outlining the employment relationship. They must comply with local labour laws and upon hiring, inform their employees of the terms of their employment.
We use our tracking list to identify suppliers for audit. We engage a specialist supply chain auditor to conduct audits and assessments on our behalf using their platform. In 2023, there were 125 external audits including 36 onsite and virtual onsite audits and 89 desktop audits. During a desktop audit, the supplier responds to an online questionnaire and uploads relevant supporting documents followed by a risk assessment using the third-party platform. For virtual onsite audits, facility representatives wear a video and audio source to allow remote interaction with a qualified auditor. The auditor can then evaluate the facility, conduct interviews, and review the necessary documentation in real-time, just as if
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conducting an in-person audit. During an onsite audit, the auditor will select employees from a full roster (and may select employees on the work floor during the facility walkthrough). Employee interviews are private and confidential and facility management is not allowed to be present. All information gathered from employee interviews is anonymised. When the auditor communicates non-compliance to facility management, they are not allowed to disclose information which could identify the employee or employees to avoid retaliation against them, which is forbidden in the Supplier Code.
The audit covers critical dimensions of the Supplier Code such as: labour (including child/forced labour, discrimination, discipline, harassment/abuse, freedom of association, labour contracts); wages and hours (including wages and benefits and working hours); health and safety (including general work facility, emergency preparedness, occupational injury, machine safety, safety hazards, chemical and hazardous material, dormitory and canteen); management systems (including documentation and records, worker feedback and participation, audits and corrective action process); environment (including legal compliance, environmental management systems, waste and air emissions); anti- corruption and data security.
During 2023, onsite and virtual audit locations included Argentina, India, Italy, Philippines,
Poland, Romania, Singapore, Sri Lanka, South Africa, and the United Kingdom. All of our third-party auditors undergo training in the Compliance Practitioner Initiative (CPI) corporate responsibility lead auditor programme.
This auditor training encompasses a range of Human Rights standards, including key articles from the United Nations Universal Declaration of Human Rights, the Fundamental Conventions of the International Labour Organization (ILO), the United Nations Guiding Principles on Business and Human Rights, and the Ethical Trading Initiative(ETI) Base Code. In addition to the CPI and global training, our country experts conduct periodic refresher training sessions covering various topics such as human trafficking, modern slavery, land rights, and other emerging issues and local laws.
When scheduling an audit, the facility is requested to provide information on the languages spoken by employees. Where necessary, external interpreters are engaged to ensure effective communication during the audit.
An incidence of non-compliance triggers a continuous improvement report summarising audit results, with remediation plans and submission dates agreed and signed by both the auditor and the supplier. The auditors review evidence of remediation which they accept or reject, working with suppliers until full compliance is reached.
RELX has a tiered approach to remediation, as detailed in the table below:
Finding Rating | Time to remediate (months) |
Zero Tolerance/Business Critical | 1 |
Major | 3 |
Moderate/Minor | 6 |
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Ensuring suppliers remediate any findings from audits is critical to confirm compliance with the Supplier Code. We have a defined process in place with increased communication both internally and externally to help suppliers remediate zero tolerance/business critical and major findings within the defined timelines. If a supplier does not remediate these findings within the deadline, we work with relevant colleagues to define next steps (e.g. alternative suppliers, exit strategy, etc.).
The Supplier Code states, "Failure to comply with any RELX term, condition, requirement, policy or procedure…may result in the cancellation of all existing orders and termination of the business relationship between RELX and supplier."
We understand audits are a helpful diagnostic tool to effectively identify risks alongside other measures. We strive for meaningful relationships with our suppliers to foster dialogue on labour and other issues.
Our suppliers and their employees can report any grievances to a dedicated RELX email inbox. We did not receive any complaints in 2023 related to human trafficking or modern slavery.
TRAINING
OUR BUSINESS
In 2023, we continued to develop our modern slavery awareness training programme to highlight the prevalence of slavery globally and to ensure our employees are equipped with an understanding of how to deal with any suspected incident of modern slavery.
We developed an e-learning module in partnership with Slave Free Alliance, a social enterprise that helps organisations protect their operations and supply chains from modern slavery. The module can be accessed through our HR learning portal by all employees.
The training helps:
Develop an understanding of what modern slavery is and the different forms that exist.
Recognise the signs and indicators of the different forms of modern slavery.
Understand how to respond appropriately if a victim or incident of modern slavery is identified.
During 2023, employees across the business undertook the training and provided feedback. Throughout 2024 we will continue to deploy training across the company, targeting teams in procurement, exhibitions, facilities, and human resources.
OUR SUPPLY CHAIN
During the year we invited suppliers on our tracking list for training on the SMETA audit process. In addition, we invited 104 suppliers during 2023 to undergo further training on preventing forced labour.
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Disclaimer
Relx plc published this content on 11 March 2024 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 13 March 2024 15:11:07 UTC.
