Anti-Slavery and Human Trafficking
INTRODUCTION
Deluxe Corporation and its subsidiaries (“Deluxe”) have a responsibility to be alert to the risks of slavery and human trafficking in our business and in our work with third party vendors and suppliers. All employees and affiliates are expected to report any concerns and management are expected to act upon them.
ORGANIZATION’S STRUCTURE
Deluxe provide products and services to financial institutions and small businesses. Deluxe has its head office in Shoreview, Minnesota, United States of America.Deluxe has an annual turnover in excess of the statutory threshold.
OUR BUSINESS
Our business is organized into three business lines including Deluxe Small BusinessServices, Deluxe Financial Services and Direct Checks.
OUR VENDORS AND SUPPLIERS
Our vendors and suppliers supply chains includes but is not limited to manufacturing of promotional materials, printers, website hosting, IT suppliers, sub-contractors and consultants.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
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 policies reflect 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.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk Deluxe, where possible, builds long standing relationships with customers, third party vendors and suppliers and makes clear our expectations of business behavior.
We have in place systems to:
- Identify, assess and monitor potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains by auditing and monitoring providers.
- Protect whistle blowers and report unethical conduct.
SUPPLIER ADHERENCE TO OUR VALUES
We have zero tolerance to slavery and human trafficking to ensure all those in our supply chain and contractors comply with our ethics. We have dedicated representatives that are aware of the requirements of Modern Slavery Act and the principles of human rights from the following departments:
- Legal
- Audit and compliance
- Human resources
- Sourcing
TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and with our customers, third party vendors and suppliers, we provide training to all relevant individuals and entities.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
We use the following to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or with our vendors or suppliers:
- Completion of contracts audits by area managers;
- Use of payroll systems; and
- Communication and training regarding Deluxebehavioral expectations with our employees and third party vendors and suppliers.
This statement will be reviewed and published annually. This Statement is for the financial year ended December 31, 2016.
Lee Schram
Chief Executive Officer & Member, Board of Directors