Legal Documents

Modern Slavery Statement

  1. Introduction

Section 54 of the Modern Slavery Act 2015 requires commercial organizations to prepare a slavery and human trafficking statement for each financial year.

Trustwave is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

This statement sets out Trustwave Limited and Trustwave Holdings, Inc. (“Trustwave”) actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the remainder of the financial year 1 April 2016 to 31 March 2017, and also for the financial year 1 April 2017 to 31 March 2018.

    1. Organizational structure and supply chains

This statement covers the activities of Trustwave:

      • Threat Management
      • Compliance Management
      • Vulnerability Management

Trustwave Holdings, Inc. currently has offices in the following countries:

      • United States of America, Canada, Mexico, Brazil, Colombia, United Kingdom, Germany, Sweden, Poland, South Africa, Israel, Singapore, Australia, New Zealand, Philippines, and Japan.

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

      • The legal team will discuss any concerns or recommendations/improvements to ensure all activities especially high risk activities carried out by the company are ethical and current.

Responsibility for Trustwave's anti-slavery initiatives is as follows

      • Policies: Legal Team
      • Investigations/due diligence: Legal Team
      • Awareness: HR Team
      • Relevant policies: Legal Team

Trustwave operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

      • Whistleblower policy: Trustwave encourages all its employees to report any concerns related to the direct activities, or the supply chains of Trustwave. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Trustwave's whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation. Employees who have concerns can contact the Whistleblower Hotline www.kpmgethicsline.com.sg or call: 0011 8000 9447853 from the US, or 00 8000 9447853 from the UK, or +65 62133232 from anywhere in the world.
      • Employee code of conduct: Trustwave's code makes clear to employees the actions and behaviour expected of them when representing Trustwave. Trustwave strives to maintain high standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
    1. Performance indicators

Trustwave has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, Trustwave is:

      • Raising awareness with employees so they have an understanding of the principles of the Modern Slavery Act 2015;
      • Introducing Modern Slavery Act 2015 or equivalent principles or legislation in its Vendor Master Agreement which will be signed by certain new suppliers.
    1. Awareness-raising programme

Trustwave has raised awareness of modern slavery issues by circulating a series of emails to employees.

The emails explain to employees:

      • the basic principles of the Modern Slavery Act 2015;
      • what steps Trustwave has taken to comply with the Modern Slavery Act 2015, and where the statement is available;
      • how can employees can report potential slavery or human trafficking issues to the relevant parties within Trustwave; and
      • what external help is available, for example through the Whistleblower Hotline.
    1. Board approval

This statement has been approved by Trustwave Limited’s board of directors, who will review and update it annually.


Robert McCullen

Date: 18 January 2017