Signifyd Modern Slavery Statement
Last updated: May 19, 2021
Policy on Human Trafficking
Slavery and human trafficking are a hidden blight on our global society. Signifyd, Inc. fully acknowledges and accepts the responsibility to be alert to the risks, however small, in our business and in the wider supply chain. 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. This statement 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 and to make suppliers and service providers aware that we promote and adhere to the requirements of the legislation.
Signifyd, Inc. considers that modern slavery encompasses:
- Human trafficking
- Forced work, through mental or physical threat
- Being owned or controlled by an employer through mental or physical abuse or the threat of abuse
- Being dehumanized, treated as a commodity or being bought or sold as property
- Being physically constrained or to have a restriction placed on freedom of movement
Signifyd, Inc. is an online fraud protection company and digital trust safety platform. Incorporated in San Jose, CA, United States in 2011, we provide digital fraud and protection services to clients within the United States and across the globe.
We are presently headquartered in San Jose, CA with additional offices in Denver, CO and New York, NY. Signifyd also operates as a limited company Signifyd UK Ltd. and has offices in Belfast and London.
Our business is organized into various core functions overseen by a senior executive team, led by our CEO and Co-founder, Rajesh Ramanand. Our core business operations include Product Development and Engineering, People Operations, Sales and Strategic Partnerships, Operations and Corporate Development, and Marketing and Finance. Each is overseen by a Vice President, Senior Vice President or Chief Officer.
Senior Leadership Team
- Rajesh Ramanand - Chief Executive Officer
- Mike Liberty - Chief Product Officer
- Emily Mikailli - SVP of People Operations
- Danny Lorenzo - Chief Sales Officer
- J. Bennett - SVP of Operations and Corporate Development
- Indy Guha - Chief Marketing Officer
- Dan Strong - Chief Finance Officer
Senior UK Leadership Team (Signifyd UK Ltd)
- J. Bennett - Company Director
- Ed Whitehead - Company Director
Signifyd is committed to continuously improving its practices to identify and eliminate any slavery and human trafficking in its supply chains, and to acting ethically and with integrity in all of its business relationships.
Signifyd uses a small range of suppliers who supply goods for sale, provide services and support our operations.
Due diligence processes
Signifyd is committed to:
- Considering modern slavery factors when making procurement decisions.
- Developing awareness of modern slavery issues.
- Encouraging suppliers and contractors to take their own action and understand their obligations to the new requirements.
- Building long-standing relationships with local suppliers and oversee suppliers and customers and make clear our expectations of business behavior.
- With regards to national or international supply chains, our point of contact is preferably with a US/UK company or branch and we expect these entities to have suitable anti-slavery and human trafficking policies and processes. We expect each entity in the supply and delivery chain to, at minimum, adopt ‘one-up’ due diligence on the next link in the chain.
- We have in place a policy that clearly outlines a system and person of contact, to encourage the reporting of concerns and the protection of whistleblowers.
- Adhering to and continually improving our Vendor Ethics Policy.
Risk assessment and management
Sub-contracting and complex supply chain management
Signifyd’s preference is to provide permanent employment to individuals who undertake work on behalf of the company. Signifyd avoids engaging in complex employment relationships or relationships that are unduly extended. While Signifyd may engage subcontractors, or Business Process Outsourcing (BPO) from time to time, we do so from recognized and reputable industry leaders, or directly as self-employed contractors engaged for limited periods for specific projects or tasks. Work undertaken by subcontractors is overseen by the manager of the engaging department and invoices for work undertaken is closely monitored by our Finance Department. It is not, under the current terms and conditions of engagement, for subcontractors to further contract their work to another supplier. All work undertaken must be delivered by the individual or individuals to which Signifyd has engaged.
Where Signifyd engages a BPO, we undertake extensive due diligence to ensure that the BPO is compliant with our code of conduct and our company values, and we regularly audit the working conditions of the BPO and the work undertaken by their employees. It is not permitted for a BPO to further contract work to parties outside of their company.
Extended or complex employment relationships
Signifyd does not engage in any extended or complex employment relationships other than direct employment of staff or subcontracting work to self-employed professionals or audited and recognized BPOs. Signifyd does not engage high numbers of agency workers or outsourced or subcontracted workers.
Presence of labor recruiters in supply chains
Signifyd recognizes that the risk of trafficking increases through the actions of labor brokers involved in the recruitment and hiring process. Therefore, Signifyd only engages reputable agency recruiters directly for permanent positions within the company. This involves a high-level check of candidates’ right to work and suitability to work for Signifyd in the location they are engaged in and complies with local labor laws. Signifyd also requires vendors to ensure they are complying with local labor laws in the use of recruitment or labor agencies and those workers’ right to undertake work does not break the local labor or human rights laws.
High flexibility and low-profit margins
Signifyd does not engage in the production or processing of large quantities of goods and is therefore not dependent upon work that may be open to exploitation. Signifyd recognizes that companies who produce high volumes and low margins and where workers are expected to work to levels of high-flexibility are at greater risk of leaving workers vulnerable. At this time, Signifyd does not engage any vendors for such goods or services.
Key performance indicators to measure the effectiveness of steps being taken
Signifyd, Inc. uses the following key performance indicators (KPIs) on an ongoing basis 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 supply and delivery chains:
- Completion of Audits by Area Managers and Business Development Managers.
- Use of workforce monitoring and payroll systems, including right-to-work checks for all UK and US employees.
- Level of communication and personal contact with the next link in the supply chain and their understanding of, and compliance with, our expectations.
- Formation of a Vendor Ethics Committee to outline requirements and standards expected of our suppliers, including procedures for managing any concerns or breaches in our Code of Conduct.
Supplier adherence to our values
Signifyd adopts a zero-tolerance approach to slavery and human trafficking. We expect all those in our supply and delivery chain and (sub)contractors to comply with our values.
The Senior Management and Executive team are responsible for compliance within their respective departments and for their supplier relationships. Extensive work is undertaken to understand the suitability of a business or agency before they are engaged to undertake work on behalf of Signifyd.
- Conducting a transparent procurement process.
- Drafting supplier agreements which include obligations around staff wellbeing and adherence to local employment and human rights legislation.
- Ongoing site visits, both pre and post-engagement, for BPOs.
- Review and auditing of supplier records.
- Review and auditing of supplier codes of practice, policies and procedures.
- Confidential interviews with supplier staff members both pre and post-engagement.
Training on modern slavery and trafficking
Senior leadership at Signifyd is responsible for the delivery of training and awareness-raising for relevant staff at Signifyd. This involves regular training on the nature of modern slavery, the risks that modern slavery presents to Signifyd, its employees and its vendors, and our commitment and responsibility to act on concerns when raised to ensure Signifyd does not belong to a network or system which permits modern slavery or exploitation to occur.
This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and constitutes Signifyd, Inc.’s slavery and human trafficking statement for the financial year ending December 31, 2020. This statement was approved by Signifyd’s Board of Directors on May 6, 2021 and signed by Signifyd’s SVP of Operations and Corporate Development, J. Bennett, on May 13, 2021.