Anti-slavery and human trafficking statement
At Pottermore, we are committed to making sure that there is no form of forced or compulsory labour or servitude, nor any other form of slavery or human trafficking, in any part of our business or supply chains.
This statement sets out our risk analysis for the financial year 2017/2018 ending 31 March 2018 and explains the steps that we have taken to fulfil our commitment.
Structure of our organisation in our 2017/2018 financial year
Pottermore Limited is the digital publishing, e-commerce, entertainment and news company of J.K. Rowling. It is a private limited company incorporated in England and Wales (registered number 6979090). Pottermore’s activities include publishing ebooks, digital audiobooks and enhanced digital editions of J.K. Rowling’s Harry Potter and wider Wizarding World books, scripts, screenplays and other content. We mainly undertake our operations through our digital platforms and social media channels.
We have a wholly owned subsidiary named Pottermore Inc., a corporation established in the state of Delaware, USA. The two companies constitute our group of companies, and unless the context otherwise requires, references to us or Pottermore below should be read as referring to our group of companies.
Headquartered in London, our staff are mainly based in the UK. We principally run our own operations in the UK and the USA, while maintaining a largely global web presence.
Our business and supply chains
Our business involves both direct-to-consumer operations and business-to-business operations. In addition to these primary activities, we also operate various ancillary businesses through joint ventures or partnerships.
Our suppliers are mainly based within the UK, and those mostly include digital service providers, order fulfilment suppliers, payment processors, data processors, delivery service providers, customer services providers, content producers, merchandise manufacturers, literary agents, marketing and public-relations consultants, professional advisers, IT and communication service providers, office suppliers and energy suppliers.
Our suppliers outside the UK are mainly based within the USA or EU, and those are mostly digital service providers, payment processors, data processors, delivery service providers, customer services providers, content producers, merchandise manufacturers and professional advisers.
Our risk analysis for our 2017/18 financial year
On the basis of the assessment of our business and supply chains carried out during the financial year, we consider that there is a relatively low risk of slavery and human trafficking within both our own business and our supply chains.
Our policies and procedures relating to slavery and human trafficking
As one of our core values, we are committed to maintaining consistently good ethical standards in all our business relationships.
We have implemented an anti-slavery and human trafficking policy to ensure that all our staff perform their duties ethically and in line with our expectations. The policy underpins our commitment to acting with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to ensure that neither slavery nor human trafficking is taking place anywhere in our business or supply chains. We also require our suppliers to take a similar approach.
Accordingly, we have put in place systems in order:
• to identify, assess and monitor potential risk areas in our business or supply chains;
• to mitigate any risk of slavery and human trafficking occurring in our business or supply chains;
• to protect our personnel from any threats of harassment, violence or intimidation; and
• to protect whistle blowers through our confidential reporting process.
In this financial year, we have also set up a dedicated anti-slavery compliance team, which consists of representatives from our legal and HR departments and seeks regular input from our accounting, procurement and sales departments. The compliance team meets regularly to help ensure that our anti-slavery policies and procedures are followed and to assess their ongoing effectiveness.
Compliance in our supply chains
We have zero tolerance to slavery and human trafficking, and we expect that in our suppliers too. To ensure that all suppliers in our supply chains comply with our values, we have put in place a procurement policy that requires:
• all our staff with responsibility for purchasing supplies from suppliers to observe diligent standards of honesty and fairness, to work in a manner that ensures due accountability and to report any perceived breach of anti-slavery rules in a timely manner; and
• all our suppliers to comply with all the requirements arising from our obligations under the Modern Slavery Act 2015, including a commitment to deal with us in a professional manner that is transparent, accountable, auditable and free from ethical ambiguities.
In our due diligence processes for suppliers, we take a risk-based approach to determine the extent and frequency of assessments. For any supplier that we perceive as potentially risky or vulnerable from an anti-slavery perspective, we conduct due diligence on it (including enhanced due diligence, where appropriate), and take any relevant best-practice guidance into account, before we allow it to become a supplier to Pottermore – specifically including due diligence on compliance with the requirements of the Modern Slavery Act. When conducting due diligence, we endeavour to assess all relevant risks, including any applicable country, sector, industry, transaction and/or product risks.
We also expect all our delivery partners and other organisations that we engage with to ensure that their own goods, materials, services, activities and labour-related supply chains are free from any form of modern slavery or human trafficking. Accordingly, we endeavour to ensure that those obligations are included as contractual obligations within our supply contracts. In particular, our standard terms and conditions of procurement and our standard supply agreements include appropriate contractual provisions to ensure that our suppliers are contractually obliged: (a) to comply with all applicable antislavery and human trafficking laws and regulations (and to warrant such compliance in the past); (b) more generally to implement and maintain suitable measures to avoid the use of slave labour and/or trafficked labour; (c) to maintain transparent and auditable records of the supply chain for all supplies provided by the supplier to Pottermore and (d) to include equivalent contractual provisions in contracts with their own suppliers. In our standard procurement and supply contracts, we also insist on a right to terminate for non-compliance by the supplier with its anti-slavery obligations.
As part of our ongoing risk mitigation process, we intend to act promptly in the event that we become aware of any anti-slavery compliance breach in business or supply chains, and to incorporate any learnings from such action into our anti-slavery risk-management process. We have not, however, become aware of any such breach in our business or supply chains during the financial year.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and supply chains, we make training available to our staff on slavery and human-trafficking risks and the requirements of the Modern Slavery Act 2015.
Our effectiveness in combating slavery and human trafficking
The policies and procedures described above are designed to reduce the risk of any slavery or human trafficking in our business or supply chains, and allow us to monitor any potential risk areas in our business and supply chains.
As noted above, our current assessment is that, based on the monitoring that we have carried out during the relevant financial year and given the nature, location and other relevant characteristics of our business operations and supply chains and various other key performance indicators, there remains a relatively low risk of slavery and human trafficking in our business and our supply chains.
Nonetheless, we are conscious of the need to remain vigilant about any such risks and to keep enhancing our effectiveness in combating any slavery and human trafficking. So our compliance team will keep evaluating our anti-slavery effectiveness over the next financial year, and we shall put in place any additional measures that may be appropriate for identifying, assessing, monitoring, measuring and mitigating any potential slavery-related risks in our business or supply chains.
This statement is made under section 54(1) of the Modern Slavery Act 2015. It is our group’s antislavery and human trafficking statement for the financial year ending 31 March 2018, and it has been approved by Pottermore’s board of directors on 26 March 2019.
Neil Blair, Director
for Pottermore Limited