INGENICO GROUP STRUCTURE AND SUPPLY CHAIN OVERVIEW
Ingenico Group SA, a French publicly listed company, is the parent of the Ingenico group of companies (“Ingenico Group”) including the two main trading entities in the UK, Ingenico (UK) Limited and Ingenico Retail Enterprise (UK) Limited (“Ingenico UK”) and the main trading entity in Australia, Ingenico International (Pacific) Pty Limited (“Ingenico AUS”). Ingenico Group is the global leader in seamless payment services, providing secure payment solutions across all sales channels. The Group is organised across two customer-centric business units – the Retail Business Unit and the Banks and Acquirers Business Unit. Ingenico Group employs nearly 9,000 people located in 46 countries. It has commercial operations in 170 countries, with sales revenues in 2019 of €3.3 billion.
As a global organisation, acting with integrity in all our business activities is of paramount importance. We strive to maintain the highest ethical standards in all engagements with our various stakeholders. In particular, we are committed to working only with suppliers and service providers who conduct business in a socially responsible manner. The most significant supply chain operations relate to the manufacturing of payment terminals, which is fully outsourced. This process is managed by Ingenico Group’s French and Chinese entities, and the payment terminals are then distributed to regional entities.
The assembly of the payment terminals is carried out by approved subcontractors who have been thoroughly evaluated and are regularly audited. Upstream from this assembly chain, Ingenico Group works with a community of suppliers to produce its various components. These product manufacturing and assembly activities are predominantly carried out in Hong Kong, China, Taiwan, Vietnam, Thailand, Malaysia and Brazil.
POLICIES AND PROCEDURES
Ingenico Group’s adherence to ethical working practices is demonstrated by its participation in the UN Global Compact. Each year, as a signatory to the Global Compact, Ingenico Group reports on the progress it has made in respecting and promoting the Global Compact’s universal principles, including in relation to human rights and international labour standards. In 2019, the Group published its report at GC Advanced level, which corresponds to a higher standard of social responsibility.
Our commitment to ensuring that there is no Modern Slavery in our supply chains or in any part of our business is also enshrined in our Code of Ethics and Business Conduct (the “Code”) , which is made available to all employees.
In 2019, Ingenico Group reviewed and made updates to the Code, which was published in early 2020, particularly in connection with Modern Slavery and other recent regulations. The Code emphasizes the ethical standards and values Ingenico’s employees and partners must abide by and includes a specific commitment relating to Modern Slavery.
“Ingenico will not tolerate any form of modern slavery, including servitude, forced or compulsory labour or human trafficking, including for example workers employed by coercion, force or blackmail.”
The Code is accessible in multiple languages to ensure that the Group’s ethical culture is fully understood and adopted by all parts of the business. The global Human Resources network also ensures that ethical working standards are consistently applied across the business. New employees are expected to acknowledge the Code. This is supported by the Internal Control Manual and internal auditors verify compliance and ensure there are no abnormal situations, such as employees not receiving minimum wages or more people working on sites than there should be.
In 2019, the Code was included in the onboarding pack of documents for new employees and sub-contractors with 70% of new employees and sub-contractors signing the Code. All Australian employees acknowledged the Code in 2019.
Additionally, Ingenico Group has an Alert Policy, which provides a mechanism for any employee or external stakeholder to report any breach or potential breach of the Code. The Alert Policy establishes a confidential Ethics Line for issues to be reported and this is administered by the Chief Executive Officer and Chief Compliance Officer of Ingenico Group.
Our rigorous approach to maintaining ethical business practices is further underlined by the existence of a dedicated Corporate Social Responsibility (CSR) function, which is responsible for managing the Group’s CSR activities. The CSR charter includes specific commitments regarding labour rights and social justice standards.
In 2019, we fully implemented a new responsible purchasing policy based on five commitments summarised in Ingenico Group’s Responsible Purchasing Charter. The second commitment of the charter is promoting high labour and human rights standards through our supply chain. The fifth is strengthening the transparency of our supply chain, avoiding conflict minerals and controversial substances in our terminals.
“We are committed to ensuring a socially responsible management of our supply chain. And this is why we require that our suppliers respect at least the following principles: […] prohibition on child and involuntary labour and human trafficking, […] respect of a decent working time, and minimum legal wages and benefits.
As a member of the electronics industry, we are committed to further strengthening the transparency of our supply chain and ensuring that the materials that go into our terminal components are not linked to human rights abuses.”
In partnership with EcoVadis, a consultancy specialising in supply chains’ CSR assessment, we conducted a social and environmental risk mapping for Ingenico terminal suppliers, component suppliers and indirect suppliers, at the end of 2018 with the following results:
Focus was made on the component suppliers categorized severe or high-risk for the deployment of CSR assessment and audits.
SUPPLIER DUE DILIGENCE, CONTRACTUAL CONTROLS, ASSESSMENTS AND AUDITS
Based on the risk mapping outcome, Ingenico Group has implemented a range of due diligence measures to assess and manage any risks of Modern Slavery within our supply chains:
Although we consider that the main Modern Slavery risks mostly relate to component manufacturing activities, we are aware of the need to remain vigilant in all supply chain operations. Procurement not related to the core manufacturing products (e.g. logistics, courier services, waste management etc.) is controlled at a local business level. Prior to contracting with any significant new suppliers, Ingenico UK uses a due diligence questionnaire, including an ethics section and a question on employment of child or forced labour.
TRAINING AND AWARENESS
A webinar is accessible to all employees on the alert mechanism and the Code of Ethics and Business Conduct. It provides details on how to confidentially report any non-compliance and clarifies that anyone reporting issues will be fully protected. This webinar was promoted during an internal Learning Week in 2019.
In addition, a dedicated Compliance Intranet site has been established with relevant policies and guidance. This has been supported by local awareness campaigns including for example, displaying information relating to the Code and Alert Policy on office screens.
In 2019, Ingenico also ran an internal awareness campaign on its responsible purchasing approach and global communications around the launch of its 5-year CSR programme called SHARE, with the recruitment of ambassadors around the world to locally relay the programme’s actions.
Our commitment to preventing slavery and human trafficking will be demonstrated by ensuring the continuous review and improvement of our systems and processes.
Further steps to be implemented will include:
We will report on progress made in future statements.
This statement is made on behalf of Ingenico Group SA and its relevant subsidiaries, including Ingenico UK and Ingenico AUS and has been approved by the Executive Committee of Ingenico Group SA. The statement was prepared in consultation with, and reviewed by the executive management of Ingenico UK and Ingenico AUS. This statement constitutes our Group's slavery and human trafficking statement for the financial year ending 31 December 2019 pursuant to section 54(1) of the Modern Slavery Act 2015 for Ingenico UK, and constitutes the modern slavery statement pursuant to section 13 of the Modern Slavery Act 2018 (Cth) for Ingenico AUS.
INGENICO GROUP – CEO