Modern Slavery Policy

Effective January 1, 2019

Introduction

The statement sets down Blinkfire Analytics’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.

Organisational structure and supply chains

This statement covers the business activities of Blinkfire Analytics which are as follows:

  1. Social Media Analytics software-as-a-service – providing a cloud-based hosted service to enable clients to analyze and benchmark social media performance against peers and competitors.
  2. Sponsorship Exposure Analytics software-as-a-service – providing a cloud-based hosted service to enable clients to analyze and report sponsorship valuation performance to their sponosors, or for sponsors to do the same for those they sponsor.

The Company currently operates across the globe, predominantly in the EU and US.

All of Blinkfire Analytics’s staff are based in the USA. Blinkfire Analytics has a wholly owned subsidiary, Blinkfire Analytics, S.A., which employs staff in the EU.

Blinkfire Analytics assesses whether particular activities or countries are high risk in relation to modern slavery or human trafficking at a board level for any concerns raised.

Responsibility for the Company’s anti-slavery initiatives is as follows:

Training

To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires all management staff to familiarize themselves with Blinkfire Analytics’s anti-slavery policy.

Policies

The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners AND/OR evaluating the modern slavery and human trafficking risks of each new supplier AND/OR invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

Performance indicators

Blinkfire Analytics measures how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains by requiring all relevant staff to have familiarized themselves with Blinkfire Analytics’s policies, and logging all reported concerns around slavery and human trafficking, together with the action taken.

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The Management Team endorses this policy statement and is fully committed to its implementation.

This Modern Slavery and Human Trafficking Statement has been approved and authorized by:

Name: Stephen Olechowski

Position: CEO