As of January 01, 2024 (View December 20, 2022 version)
Introduction
Section 54 of the United Kingdom Modern Slavery Act 2015 requires companies which carry on a business, or part of a business, in any part of the UK to publish an annual statement specifying the efforts taken to help prevent slavery and human trafficking in their own business or their supply chain. Intuit Limited’s statement, for the financial year ended July 31, 2023, was approved by the Board of Directors of Intuit Limited on December 18, 2023, and signed by Deborah Wickstead, Vice President of Finance for the UK.
Our operating values are core to our culture and define how we operate.Our value of 'integrity without compromise' ensures we speak the truth and value trust above all else and we do the right thing, even when no one is looking.We strengthen the communities around us, and we strive to give everyone the opportunity to prosper. As part of this, we are committed to addressing modern slavery and human trafficking risks in our business and supply chain, even if we do consider that this is a low risk for Intuit.
Company Overview and Organisational Structure
Intuit is the global financial technology platform that powers prosperity for the people and communities we serve. With 100 million customers worldwide using TurboTax, Credit Karma, QuickBooks, and Mailchimp, we believe that everyone should have the opportunity to prosper. We never stop working to find new, innovative ways to make that possible.Intuit Inc. (Nasdaq: INTU) is headquartered in Mountain View, California, United States. Intuit Inc. and as of 31st July 2023 the Intuit group companies (collectively “Intuit group”) employ approximately 18,200 employees worldwide. More information on its business can be found in its annual 10-K filing and its annual corporate responsibility report which are available on the Investor Relations and Corporate Responsibility pages of Intuit’s website (https://www.intuit.com/company/).
Intuit Limited is a wholly-owned subsidiary of Intuit Inc. with approximately 320 local employees and operates in the United Kingdom. It provides Intuit’s QuickBooks smart accounting software to sole traders, small businesses, and accountants, licensing its product to customers in the UK and overseas. As a subsidiary of Intuit Inc., Intuit Limited benefits from group-level arrangements and resources, as well as complying with group policies and procedures.
Supply Chains
Intuit Limited relies on the support of suppliers managed by our local and global procurement specialists. In some cases, the ultimate suppliers to Intuit Limited are procured and managed by Intuit Inc. via sub-contracting or group contracting arrangements. Our primary suppliers deliver the following categories of supply:
- Technology (e.g. software, hardware, support)
- Office (e.g. facilities management, food and drink)
- Sales and marketing (e.g. advertising, designers)
- Professional Services (e.g. lawyers, accountants, consultants)
- People (e.g. recruiters, training providers)
- Business Travel (national and international)
Codes & Policies
Our workforce and suppliers are some of our most valued partners. We communicate our expectations to them:
- WORKFORCE: We expect all employees to live by Intuit’s values. Our Code of Conduct & Ethics (the “Code”) serves as a further guide to employee conduct, and all workers must agree to abide by the Code. The Code applies to Intuit group’s global workforce and sets out our core value (which is also an operating value), “integrity without compromise”. We require our employees, agency workers, independent contractors and other contingent workers (collectively, “Workforce”) to conduct themselves ethically, professionally and with the utmost integrity and transparency in all of their business dealings, including complying with all applicable laws, rules, and regulations. The Code reinforces our commitment to a safe, ethical, and inclusive work environment. It also provides important information about our company policies and further information about our values, and applicable laws and regulations. The Code is acknowledged by our Workforce as part of their on-boarding process and biennially thereafter. We adopt policies and procedures to ensure compliance with the Code and all applicable laws and regulations.
- SUPPLIERS: Our Supplier Code of Conduct (“Supplier Code”) serves to guide supplier business conduct, and all suppliers across the Intuit group must agree to abide by the Supplier Code. We require our business partners, suppliers, contractors and agents (collectively, “Suppliers”) to conduct themselves ethically, professionally and with the utmost integrity and transparency in all of their business dealings, including complying with all applicable laws, rules and regulations. The Supplier Code requires Suppliers to respect and protect fundamental human rights across their value chain in accordance with international standards set forth by the United Nations Universal Declaration of Human Rights, which prohibits slavery, and the International Labor Organization’s Fundamental Convention on Discrimination (Employment and Occupation). Specifically, the Supplier Code provides that all work should be voluntarily performed and prohibits forced, bonded, or indentured labour and involuntary prison labour. Additionally, Suppliers must provide a safe and hygienic workplace, a freely chosen environment for workers and equal employment opportunities. The Supplier Code is acknowledged by our Suppliers as part of our supplier on-boarding process. We require our Suppliers to establish policies and procedures to ensure compliance with the Supplier Code and all applicable laws and regulations.
- BOTH: We want our Workforce and Suppliers to raise concerns through whatever reporting channel they are most comfortable using. We have an externally-managed Intuit Integrity Line for our Workforce and our Suppliers to report suspected conduct that may not align with our Code or Supplier Code. Both our Workforce and our Suppliers are also encouraged to report any illegal activities to the Intuit Integrity Line. They can choose to identify themselves and let us know how to reach them for additional information, or they can remain anonymous.
We prohibit retaliation against anyone who reports a concern in good faith. The Intuit Integrity Line is available to protect third-party personnel, temporary workers, independent contractors, and personnel of subcontractors. In the event we become aware of a policy violation or behaviours related to slavery and human trafficking, our legal or HR departments would determine any necessary actions.
Our Global Human Rights Policy sets out how we will use voluntary labour only and that we oppose all forms of forced labour, unlawful child labour, prison labour, and human trafficking.
Other Intuit group policies support the Code, Supplier Code and Global Human Rights Policy such as the Intuit group’s policy on recruitment and use of contingent workers, and our purchasing policy which provides procedures for how to acquire goods, services and intellectual property so that all activities are conducted in accordance with applicable laws and regulations where Intuit has a business presence.
Due Diligence
As part of our actions to help prevent forced labour, slavery and human trafficking, we use risk-based due diligence and contractual measures on our Workforce and Suppliers:
- WORKFORCE: For employees and contingent workers, Intuit Limited has robust recruitment processes, which include common employment screening checks such as the right to work in the United Kingdom, and the use of standard employment contracts under which our Workforce agrees to all of our policies, procedures and requirements, including the Code.
- SUPPLIERS: For Suppliers, we use a third-party risk management solution to risk screen, assess, onboard, manage, and monitor our third parties, as well as standard purchase order terms under which Suppliers agree to all of our policies, procedures, and requirements, including the Supplier Code and comply with all applicable laws and regulations. This may include reviewing a relevant supplier’s Modern Slavery Act statement or policies.
- BOTH: Both groups are screened against government watch lists and subject to adverse media searches. In the event an issue is discovered during screening, appropriate action will be taken.
We generally have the right to perform evaluations to ensure that our Suppliers, their subcontractors, and their next-tier suppliers are complying with our Supplier Code and with applicable laws and regulations. This includes the right to visit (and/or have external monitors visit) supplier facilities, with or without notice, to assess compliance with the Supplier Code and the law. We may take measures to ensure compliance and address suspected instances of non-compliance with the Supplier Code. This can ultimately include the termination of relationships with Suppliers where we are not satisfied with a supplier’s response, and notification to the relevant authorities.
Risk Management
We use the following factors, among others, to determine potential vulnerability to our business:
- Country risk: Suppliers may be in low-risk jurisdictions such as the UK, the EU, or the USA, but they may use overseas operations such as for low-cost manufacturing or outsourcing centres from jurisdictions considered high-risk.
- Sector risk: Suppliers may deliver goods and services (e.g. technology, promotional materials, food or office consumables) whose components may originate from sectors more susceptible to modern slavery risks and low-skilled labour.
- Business partnership risk: Suppliers may have varying types of relationships, from project-specific and business unit specific engagements to long-term and company-wide dealings. All variations pose risks.
In our operations, we identified and assessed the risk, and concluded that it is generally low. For example, we have robust recruitment and wages practices, we have processes to monitor implementation, and our Workforce is primarily skilled labour. Even though technology companies and their suppliers may be considered lower-risk than some other sectors, we are not complacent. We pursue and implement our policies rigorously and adopt appropriate measures to manage these risks.
With respect to our supply chain, identification and assessment of the risk may be more challenging, particularly where Suppliers use international third-party subcontractors in their supply chain. Specific risk areas involve managing our facilities, sourcing information technology hardware, and purchasing promotional merchandise. Our procurement and business teams monitor the delivery and relationship with Suppliers.
In this financial year and up to today’s date, we have identified no breaches and received no allegations of modern slavery or human trafficking in our business or supply chain.
Training
The Intuit group conducts employee training on workplace safety and the Code. This is supplemented with information and guidance on our policies and procedures (e.g., Integrity Line, Purchasing) on our intranet which is available to our Workforce. This year, we created and shared a new pathway training course on combating modern slavery with key individuals in our business, including Legal and Compliance and Sourcing and Procurement.
We also expect our Suppliers to communicate the principles in our Supplier Code to their employees and throughout their respective supply chains as appropriate.
Application
This is the statement of Intuit Limited only. When we make reference to group policies and procedures, this is because such policies are applicable to Intuit Limited and support its compliance with applicable UK legislation. However, nothing here should be taken as an acceptance or submission by any member of the Intuit group other than Intuit Limited to the applicability of the UK’s Modern Slavery Act 2015.
