Smartly Group Modern Slavery Statement

This statement is a Group statement made by Smartly Solutions OY, as the ultimate parent company, on behalf of the companies in the Smartly group of companies and is made pursuant to s.54(1) of the Modern Slavery Act 2015. It sets out the steps that Smartly has taken and will continue to take to ensure that modern slavery or human trafficking is prevented in our business and in our supply chain on a Group basis. This Statement covers all Smartly companies including those operating in the United Kingdom who are required by the Modern Slavery Act 2015 to publish a statement and those operating in Australia, Smartly Solutions Pty Ltd, ACN: 626 909 671, whose registered office is Level 11, 1 Margaret Street, Sydney, NSW 2000, and who is covered by the Modern Slavery Act (2018) (Cth) and including, but not limited to, Smartly Solutions Oy.

Smartly is committed to understanding potential modern slavery risks related to our business and ensuring that there is no modern slavery in our own business and supply chains. We do not condone modern slavery in any form and Smartly and the companies in the group, fully endorse and comply with the principles set out in the Modern Slavery Act 2015 and all applicable laws in the countries in which it operates.

Our business

Smartly is a privately held company  headquartered at Elielinaukio 2 G, FI-0100 Helsinki, Finland. It has offices in Argentina, Australia, Brazil, France, Germany, Ireland, Japan, Netherlands, Singapore, Spain, UAE and USA, and has over 400 employees.

Smartly offers online advertising and marketing services through its automated digital advertising platform. The platform offers marketing solutions for creative and performance marketers, across a range of social media websites including Facebook, Pinterest and Snapchat. The solutions offered include Dynamic Ads, Automated Ads and Automated Post Boosting. Smartly also provides tools to enable the management of online marketing campaigns and the customisable reporting of performance.

Our policies

We have a range of corporate policies such as our Anti-bribery and Corruption Compliance Policy and Culture Handbook, that guide the way our employees work. We are committed to responsible operations in our economic, social and environmental activities and our codes of conduct [https://www.smartly.io/corporate-social-responsibility] reflect our corporate responsibility by establishing a set of common standards we expect our employees, as well as our suppliers, customers and vendors, to maintain.

Our Code of Conduct, which applies to all employees as well as contractors, consultants, suppliers, and agents in connection with their work for Smartly, states that we respect and uphold human rights, follow all applicable laws, prohibit bribery, protect confidentiality, respect the environment, deal fairly with others and maintain a safe, healthy and discrimination-free workplace at all times.

Our Customer and Vendor Code of Conduct states that we require all of our customers and vendors to operate within the law, adhering to high standards regarding human rights, fairness and equal opportunity, to act ethically, responsibly and in accordance with environmental sustainability, and to protect whistleblowers. We will only engage customers and vendors who are able to demonstrate their shared commitment to these values.

As our employees, suppliers, customers and vendors must abide by our codes of conduct, this ensures that they act with integrity, in accordance with applicable legislation, our core values and company policies. It also provides our investors, customers and suppliers with information about these principles according to which we operate and expect our suppliers to operate. This is consistent with our Social Mission Statement, which underlines our commitment to promote trust, equality, diversity, accountability, and learning through our work and company practices.

Our interaction with suppliers

In light of where we do business, where our suppliers are based, including but not limited to, Finland, Germany, United Kingdom and the United States, and the industry in which we operate, our assessment is that there is a low-moderate risk that modern slavery and human trafficking exists in our supply chain that would affect our business.  

We purchase professional services, IT equipment, cloud computing, technology services,  and office materials, among other things, from third party suppliers and strive to conduct business with third party suppliers who share our commitment to high ethical standards and who operate in a responsible and ethical manner towards their workers and suppliers, in line with our codes of conduct. We choose our suppliers with care and their integrity and ethical business practices form part of the selection criteria and we will monitor our suppliers to assure ourselves that they remain in line with our requirements and our ethical standards. Our suppliers are generally part of a global network and therefore, each of our local offices partners with the same global suppliers. Our arrangements with suppliers tend to be structured as longer-term relationships.

Should we become aware of any policy violations or issues related to slavery or human trafficking, we will consult with our Legal Team and/or Compliance Committee to ensure that appropriate measures are taken, which may include reporting this information to authorities and terminating our relationship with the supplier.

The approach within Smartly

Smartly is dedicated to ensuring that human rights are respected at all times. We expect our employees to maintain the highest ethical standards and comply with all applicable laws and company policies. Our Code of Conduct embodies our requirements.

Smartly encourages its team members to report any suspected wrongdoing or dangers in relation to any activity that falls short of our Code of Conduct.  By encouraging a culture of openness and accountability within Smartly, we believe that it can help prevent illegal or unethical practices from occurring. Our culture is designed to make it easy for our team members to ask questions and make disclosures without fear of retaliation.

Risk assessment

Considering our business consists of predominantly professionally qualified and highly skilled people and the lengths of our supply chains are relatively short, we assess the risk of modern slavery within our business and supply chain to be low-moderate. However, we are committed to preventing slavery in all of our corporate activities and we will work in order to ensure that our supply chains are free from slavery and forced or compulsory labour.  

Smartly takes the following actions to address risks of modern slavery:

• requesting information from direct suppliers about sub-suppliers (including country of origin);
• engaging with key suppliers to understand their business and how they address their own modern slavery risks;
• assigning responsibility for assessing and addressing modern slavery risks to a senior manager;
• bringing together key areas such as legal, operations, security, human resources and senior leadership to help assess and respond to risks.

Performance indicators and measuring effectiveness

We accept that effective action to prevent modern slavery and human trafficking in our business and supply chain requires constant monitoring and an effective response should issues be identified. We are evaluating measures that can provide us with meaningful information on the efficiency of our anti-slavery stance.

Smartly has processes in place to assess the effectiveness of its actions including:

• checking risk assessment processes to ensure they are up to date;
• tracking actions taken and measuring their impact;
• setting up processes to provide engagement and feedback between different business areas such as operations, security, human resources and legal.

Our management will continue to take a zero-tolerance approach to modern slavery and human trafficking and will react accordingly to any transgression whether by our staff or by our suppliers.

A progressive approach to modern slavery

Smartly recognises that the risks from modern slavery and human trafficking are constantly evolving. We also recognise that efficient methods to identify and address modern slavery and human trafficking will be developed and enhanced. Smartly will continue to monitor and evaluate such developments and our approach to preventing modern slavery will be reviewed annually so that we can constantly adapt and improve our approach.

Training

Smartly is adjusting its employee orientation and annual training to address those aspects of modern slavery and human trafficking that are relevant to them and the way they work.

Approval

This statement is made for the financial year ending December 31, 2020. The Statement has been approved by the Board of Directors of Smartly Solutions Oy on 21 December 2020 and was signed on its behalf by Kristo Ovaska who is the CEO of Smartly Solutions OY and a Director of the Board.