GROUPON - MODERN SLAVERY ACT TRANSPARENCY STATEMENT
MyCityDeal Ltd, Groupon Shop Ltd, Groupon International Travel GmbH, and Groupon Goods Global GmbH (together, “Groupon“)
The Modern Slavery Act 2015 (the “Act”) is an Act of the Parliament of the United Kingdom. It is designed to tackle slavery in the UK, and consolidates previous offences relating to human trafficking and slavery. The Act also introduced a new corporate reporting obligation requiring companies that qualify to set out the steps they are taking to tackle modern slavery issues in their businesses and supply chains. Groupon is in compliance with this new obligation. You can click here to learn more about the Act.
At Groupon, we believe we have a responsibility to ensure that our business is conducted in an ethical way, and we actively engage to address social issues. We realise that modern slavery is such an issue, and take seriously our responsibility to comply with the Act and to assist in preventing and combating slavery and human trafficking where possible.
As such, we are issuing this Modern Slavery Act Transparency Statement, which includes a description of our organizational structure, merchants and supply chain, efforts to identify and mitigate the risk of slavery and human trafficking in our supply chain, and information about how to report concerns or complaints arising under or related to the Act.
Groupon is part of a global e-commerce marketplace. Groupon Inc. is the ultimate parent company of the entities that make up Groupon. Groupon Inc. is headquartered in the United States (Chicago, Illinois).
MERCHANTS AND SUPPLY CHAIN
Groupon's merchants, vendors, and suppliers (together, “Merchants”) include but are not limited to:
Merchants for whose services or goods MyCityDeal Ltd sells vouchers;
Merchants who sell goods to Groupon Goods Global GmbH and Groupon Shop Ltd (together, “Goods Merchants”);
Merchants for whom Groupon International Travel GmbH sells vouchers or makes available other travel-related products; and
Merchants who provide office-related operations (e.g., cleaning, catering, stationary, etc.)
Groupon takes a risk-based approach as part of our initiative to identify and mitigate slavery and human trafficking occurring in our supply chain:
We directly ask potential Goods Merchants whether they “engage in child labour, slavery, forced labour and/or human trafficking” in our Groupon Vendor Vetting Questionnaire. We refuse to do business with potential Goods Merchants who respond that they in fact engage in any or all of these practices. Our existing Goods Merchants must also complete the Goods Vendor Vetting Questionnaire on an annual basis to recertify their responses, including recertifying their response to the abovementioned question. If a current Goods Merchant indicates during the annual recertification process that it has begun engaging in child labour, slavery, forced labour, and/or human trafficking, Groupon will cease doing business with this Goods Merchant;
We ask our Merchants to confirm in our agreements with them that they comply with all applicable international, federal, state, local, and other laws, which would include laws related to child labour, slavery, forced labour and/or human trafficking, as well as all applicable policies (specifically including the Global Vendor Code of Conduct described in further detail below). In our EMEA vendor portal, we have a line item on compliance with modern slavery legislation requirements, and we state “Groupon complies with the UK Modern Slavery Act 2015 (the "Act") and any similar applicable legislation regarding modern slavery or human trafficking, and requires that all its business partners take reasonable steps to ensure that there is no modern slavery or human trafficking in their supply chains or in any part of their business. For more information, review the Act and Groupon's Vendor Code of Conduct.” Further, the agreements issued by our UK entities specifically require each Merchant to warrant, represent, and undertake that “it complies with the UK Modern Slavery Act 2015 and any similar applicable legislation regarding modern slavery or human trafficking, and takes reasonable steps to ensure that there is no modern slavery or human trafficking in its supply chains or in any part of its business”; and
We provide several methods for both employees and non-employees to report their concerns and complaints about modern slavery practices to Groupon’s Compliance Team, including by using our ethics hotline, EthicsPoint. We make clear in our policies that employees who report their concerns or complaints regarding violations of applicable laws or policies in good faith shall not be penalised.
Vendor Code of Conduct
Groupon, Inc. has put in place a Global Vendor Code of Conduct (the “Vendor Code”) that sets out our requirements for all Merchants who do business with or on behalf of Groupon, Inc. This Vendor Code is displayed on all of the country-specific Groupon websites and is translated into our standard languages. It is also made binding on Merchants through our agreements with them.
The Vendor Code specifically states that Groupon, Inc. prohibits Merchants from engaging in child labour as well as any form of coerced labour such as slave labour, prison labour, indentured labour, bonded labour, and any other form of involuntary servitude. The Vendor Code also states that all Merchants are responsible for monitoring their global supply chains to ensure compliance with applicable coerced labour and human trafficking laws.
Anyone who has knowledge of an actual or potential violation of the Vendor Code is asked to make a report using the methods described in the Monitoring and Reporting section below.
UK Whistleblower Policy
Groupon’s UK Whistleblower Policy, which pertains to all employees, contractors, consultants, and agency staff who work for Groupon in the UK, provides information about raising concerns and complaints arising under or related to the Act, and provides methods for reporting such concerns and complaints, which are also detailed in the Monitoring and Reporting section below.
Groupon provides training to its employees regarding the policies and processes it has in place to combat slavery and human trafficking and the reporting mechanisms available to employees and non-employees to report concerns and complaints arising under or related to the Act. This training is provided to new and recently-promoted employees at a certain level on a quarterly basis, and every two years thereafter. The last such training was provided in October 2018.
MONITORING AND REPORTING
Concerns and complaints arising under or related to the Act should be reported to the Compliance Team at firstname.lastname@example.org or via EthicsPoint at gr.pn/ethicspoint. EthicsPoint complaints may be made anonymously.
The Compliance Team will promptly investigate any concerns and complaints arising under or related to the Act and/or the objectives set out in this Statement.
This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Groupon’s slavery and human trafficking Statement for the current financial year. It has been approved by the MyCityDeal Ltd. Board.
Managing Director, Northern Europe
Board Member, MyCityDeal Ltd. Board
Date: November 12, 2018