Preamble

At Incubeta we support and take seriously our duty in the protection of human rights around the globe. As part of our duty we are committed to ensuring that all forms of human trafficking or modern slavery do not take place within our business and supply chain.

This Modern Slavery Statement is made on behalf of the Incubeta group of companies with regards to its company located in the United Kingdom, Incubeta UK Limited (“Incubeta”), as required by section 54(1) of the UK Modern Slavery Act 2015 (“Act”). The Act requires Incubeta to communicate its efforts and actions taken to ensure that no forms of modern slavery are taking place in our business. This Modern Slavery Statement covers our 2021 financial year (January 1 – December 31, 2021).

About us

Incubeta is a market leading specialist that uses the power of digital to unlock and amplify business growth potential through bespoke, localised digital solutions with global expertise. With 20+ years of experience in the digital space, Incubeta puts the ownership and control of the customer experience back in the hands of the advertiser.

As the largest and longest established GMP sales partner in EMEA and APAC, Incubeta has proven through working with top-tier brands that they are leading specialists in helping advertisers tackle complex projects such as in-housing, dynamic creative, data activation, real 1:1 marketing, and industry-specific segmentation modelling. Incubeta is primed to help advertisers deliver complex use cases across Google’s Maturity Framework and Menu of Services.

We are a limited liability company registered in England and Wales with company number 05188612 and are fully owned by Incubeta Holdings International Limited which forms part of the Incubeta Group with presence in over 15 countries.

Approach

As a digital service provider we have a reduced supply chain and we estimate the risk of modern slavery in our supply chain to be considerably low. We do not act as a producer, manufacturer, retailer or distributor of goods. As a digital service provider, our supply chain is straightforward and limited in comparison to other industries.

Despite the reduced risk of modern slavery, we work to the highest standards to ensure that no modern slavary occurs within any of our business operations. We have a zero tolerance policy towards any form of moden slavery and we work diligently to ensure that our suppliers, partners and independent contractors follow the same diligent standards against modern slavery.

Our actions

Our policies reject any form of slavery and communicate our approach to our employees and third parties. Our policies include:

• Risk Management Program and Risk Management Tool. This allows us to identify risks in our operations and to mitigate and monitor them.
• Code of Conduct, which makes clear that Incubeta conducts business consistent with the highest ethical and professional standards and will not tolerate behaviour that deviates from those standards.
• We conduct employment checks on any new employee that joins the business to ensure that they have the eligibility to work in the relevant country, so as such to mitigate the risk of human trafficking or of such individuals being forced to work against their will.
• We have clear policies in place for all our employees to raise any concerns in a confidential manner that they might have in relation to their employment or how individuals are being treated, without repercussions
• We have a clear Health and Safety policy set out to ensure we provide a healthy working environment for our staff that work out of our premises.
• We are fully compliant with the UK National Minimum Wage Act 1998. All staff are paid over the minimum wage and we perform annual salary benchmarking to ensure our staff are paid at industry standards.

As a company we never stand still and will continue to develop this over the course of the year where we will also be completing the following:

• We are in the process of implementing measures to identify and mitigate any risks in relation to current and future suppliers and partners on an active basis. This will include providing risk assessments to suppliers to confirm that no slavery occurs anywhere in the supplier’s business.
• Training will be implemented for employees where appropriate.
• We will continue to monitor our risks and our approach to modern slavery to make improvements where necessary.
• This statement will be reviewed annually.

This Modern Slavery Statement has been reviewed by Incubeta UK’s Leadership Team and has been approved by Incubeta’s UK CEO.