Modern Slavery Statement

Modern Slavery Statement for the Financial Year Ending 30 June 2020

For almost 70 years, Automatic Data Processing, Inc. (ADP) as a multinational corporation through its many subsidiary entities1, has served as a trusted human resources, payroll and benefits partner to employers around the world. Our mission is to provide insightful solutions that drive value and success for our clients by allowing them to focus on their business.

Today, we serve more than 860,000 clients, ranging from small, start-up businesses with a handful of employees to large, multinational companies with tens of thousands of employees spanning the globe. From our humble beginnings as a local New Jersey business in 1949, we have expanded to become one of the world’s largest global business-to-business outsourcers with more than 58,000 associates.

As a global corporate citizen, ADP recognizes its responsibility to give back to and generate a lasting, positive impact on the communities in which we operate. This commitment to corporate social responsibility (CSR) is a core pillar of ADP’s Mission, Vision and Values, and encompasses everything from philanthropy, volunteerism and environmental stewardship to diversity, corporate governance, ethics, data privacy and data security.

At ADP, we see our success and the rights of citizens as inextricably linked. We also firmly believe that businesses can and should have a positive impact on the world. That’s why we constantly strive to embed our CSR principles and practices into everything we do.

Our commitment to minimizing the risk of modern slavery and embedding our broader CSR principles is memorialized in our Code of Business Conduct and Ethics (the “Code”), which states that “[e]ach person must be accorded equal opportunity, without regard to their race, color, creed religion, national origin….”. In April 2017, we revised the Code to expressly state that ADP’s approach to human rights is consistent with the United Nations Universal Declaration of Human Rights. These principles prohibit use of any form of slave, forced, bonded, indentured or involuntary labor and require full compliance with the U.K. Modern Slavery Act of 2015 and Modern Slavery Act 2018 (Cth) of Australia. All of our associates receive annual training on the Code and are required to provide an acknowledgement of acceptance. Specific training on modern slavery is also provided to relevant associates annually to help them identify and mitigate modern slavery in the supply chain or operations.

Using internal and external resources, ADP monitors labor laws within the jurisdictions in which we operate in order to recruit and employ our associates in accordance with applicable laws, including age requirements, remuneration, working hours and conditions and we hire our associates in accordance with those laws. Upon hire, associates are provided materials and training that detail the policies and values core to ADP business.

In addition, the ADP Vendor Code of Conduct, which we adopted in 2016 and is regularly reviewed, includes similar principles to the Code and specifically requires our vendors to comply with modern slavery laws globally, which include the U.K. Modern Slavery Act of 2015 and Modern Slavery Act 2018 (Cth) of Australia. Since its adoption, we have incorporated the Vendor Code of Conduct into vendor contracts, which imposes contractual obligations on our vendors to comply with modern slavery laws with rights for ADP to terminate vendor contracts for failure to meet required standards. It is our goal that each and every ADP vendor around the globe comply with the principles set forth in our Vendor Code of Conduct. ADP engages thousands of vendors for a range of services, including supply by non-trade or unskilled workers to semi-skilled and professionals. ADP conducts due diligence and risk assessment on all vendors irrespective of the nature of service provided, be it security or cleaning vendors, or business consultants or software developers. Towards that end, in addition to the contractual obligations regarding vendor conduct, our comprehensive vendor assurance process requires all prospective vendors to respond to direct questions regarding any use of forced labor and we will not enter into any agreements with any vendor who answers such questions in the affirmative. The vendor assurance process is a centralized model for all vendor engagements globally and is conducted by ADP’s dedicated global procurement team, with applicable consultation with relevant ADP subsidiary entities, including support on vendor due diligence, liaising with vendors, and the contracting process. During our 2018 fiscal year, we implemented a governance, risk and compliance solution which, among other things, provides us with an automated means to request and track certifications, including for vendor re-assessments, from our vendors regarding the status of their compliance with specified legal and/or contractual obligations, including the requirements of modern slavery laws such as the U.K. Modern Slavery Act of 2015 and more recently the Modern Slavery Act 2018 (Cth) of Australia.

The Code, the Vendor Code of Conduct and the governance, risk and compliance solution are periodically reviewed, including an internal audit of the vendor assurance process, to assess their effectiveness. While recognising that risks of modern slavery may exist in some of our supply chains, based on these measures, the nature of services provided by ADP, and the vendors engaged to support the provision of services and operations, the risk of modern slavery is considered low within ADP, including for its subsidiaries in Australia and UK, and its supply chains.

This statement is published on behalf of Automatic Data Processing Limited ACN 003 924 945 (ADP AU), under the Modern Slavery Act 2018 (Cth) of Australia. ADP AU is an indirect wholly owned subsidiary of ADP, registered in Australia as an unlisted public company with approximately 350 associates providing payroll and human capital management services to over 6,500 clients. ADP AU engages hundreds of vendors in Australia for a range of services, including cleaning, printing services, software and hardware providers, network services, building works, professional and IT infrastructure. ADP conducts the same due diligence and risk assessment on all these vendors as outlined above, including consultation with ADP AU as required. ADP is responsible for ADP's broader CSR program, including modern slavery and human trafficking initiatives, policies and processes within its subsidiaries and has prepared this statement in consultation with ADP AU for purposes of the Modern Slavery Act 2018 (Cth) of Australia.

Effective on the 11th day of November 2020, this Modern Slavery Statement, covering the period from July 1, 2019 to June 30, 2020, has been duly approved and adopted by the ADP Board of Directors.

Carlos Rodriguez

Carlos Rodriguez
Director & Chief Executive Officer

1 Subsidiaries include, without limitation, Automatic Data Processing Limited, Business Management Systems Limited, ADP RPO UK Limited, ADP Network Services Limited, ADP Development Limited, and GSI UK Limited