SDL Modern Slavery Act Statement

This statement is made on behalf of SDL PLC and its subsidiaries pursuant to section 54(1) of the Modern Slavery Act 2015.

Introduction from the Chair

Slavery and human trafficking remains a hidden blight on our global society. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. SDL is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain, and imposes the same high standards on its suppliers, contractors and other business partners. SDL takes its responsibilities seriously and this statement constitutes its compliance pursuant to section 54 (1) of the Modern Slavery Act 2015 (the Act) for the financial year ending 31 December 2017.

Organisation Structure

SDL delivers language translation technology, services and content management. The world’s most important brands trust our comprehensive combination of global digital content management and language translation tools and services to create meaningful digital customer experiences. As a technology group we purchase software, hardware and labour from suppliers worldwide. For more information visit the SDL website at www.sdl.com.

Scope of the Modern Slavery Act 2015

The Act defines modern slavery as "slavery, servitude and forced or compulsory labour" and "human trafficking" (Modern Slavery). The Act requires commercial organisations operating in the UK (i.e. that supply goods or services from or to the UK) and have a global turnover above £36 million, to publish a statement each financial year, which sets out the steps they have taken to ensure there is no Modern Slavery in their business or supply chains.

Policies

SDL undertakes a zero-tolerance approach to Modern Slavery within its global organization and supply chain. SDL launched its Global Code of Conduct in January 2017 which detailed its ethical conduct requirements for all employees, contractors and suppliers. This was followed up with mandatory training for all employees and contractors and SDL has over a 95% completion and success rate.

SDL has implemented steps within its procurement team to ensure that we only work with suppliers who abide by our Global Code of Conduct or adhere to similar principals and ethical guidelines. SDL has adopted a risk based approach to Modern Slavery and identified high risk territories in which SDL has ensured that employees have completed the relevant training and are aware on how to identify unethical behaviour. SDL has a Whistle Blowing Policy and a dedicated Ethics Compliance team which investigate all claims of unethical behaviour.

Ethical Compliance is examined by the Board with regular reviews from the Head of Compliance via the Audit Committee.

Due diligence

SDL considers the risk of Modern Slavery existing within our business to be low. However, SDL has undertaken a detailed review of the principal regions in which it operates to ensure compliance with the Global Code of Conduct, and further amended its agreements with partners and freelancers to ensure this important issue is addressed. However SDL will be asking all its offices worldwide to complete a risk based questionnaire over a phased period to ensure that any gaps are identified and remedied.

Board Approval

This statement was approved by the Board of Directors of SDL PLC on 31 January 2018.

David Clayton
Chairman