Modern Slavery, which includes slavery, servitude, forced labor and human trafficking, is an issue of increasing global concern, affecting all sectors, regions and economies. As a global company, CSG is committed to 1) ensuring that our business practices do not support, encourage or permit slavery and human trafficking in any form, 2) understanding and working to eliminate any Modern Slavery risks within our operations and supply chain and 3) complying with all applicable laws with respect to the prevention of Modern Slavery in every country where we do business. This Statement sets out CSG’s actions to understand and address any potential Modern Slavery risks related to its business and supply chain.
CSG is one of the world’s leading revenue management and digital monetization, customer experience and payment solutions providers, and a trusted partner to some of the most wellknown companies around the globe. We leverage more than 35 years of experience to help our clients simplify the complexity of a rapidly changing business landscape. CSG has more than 4,000 employees worldwide and provides services in more than 20 countries. Our headquarters are based in Colorado, United States. The majority of CSG’s international offerings are managed services and technology solutions. CSG uses developers to create and support the software that forms the backbone of its solutions and procures supporting software from third-party vendors. Our third-party technology and services vendors are primarily based in the United States. Within the United States, CSG also provides print and mail services. For our print and mail services, we procure production hardware and other tangible inputs from vendors and suppliers who are primarily based in the United States. We consider our supply chain to be very limited and low risk for Modern Slavery.
Despite the low-risk nature of our business, we are committed to working to understand and address any risks of Modern Slavery in our supply chain and in our business.
CSG has the following policies that reflect the company’s position and its approach to the identification of Modern Slavery risks and the steps to be taken to prevent Modern Slavery in its operations:
• CSG Code of Ethics and Business Conduct: Our Code of Ethics and Business Conduct ensures the continued integrity of our business dealings. Our Code of Conduct outlines the behavior necessary to uphold CSG’s high ethical standards, including our commitment to human rights. New hires are required to provide an affirmation that they have read and understand the Code of Conduct, will comply with it, and will report suspected violations as required by the Code. All employees are required to complete additional training and provide a new affirmation annually. Compliance with these requirements is a condition of employment and is taken very seriously.
• Whistleblowing Policy: CSG takes all forms of non-compliance with our Code of Conduct very seriously. This policy is designed to assist any employee who has knowledge of noncompliance by providing a process by which relevant issues can be reported confidentially and without fear of retaliation. This includes the reporting of any circumstances that may give rise to any risk of Modern Slavery. We have an Ethics and Compliance team that reviews and investigates reports on non-compliance with our Code of Conduct.
To ensure that all those in our supply chain comply with our ethical standards, we are taking the following measures:
• Third Party Code of Conduct: CSG is committed to uncompromised integrity and ethical behavior in everything it does. These principles are the foundation of our success and must be sustained throughout every business relationship. CSG expects all of its agents, consultants, contractors, distributors and suppliers, as well as their respective employees, agents and subcontractors, to operate under the same high standards while conducting business on CSG’s behalf. CSG has instituted a Supplier Code of Conduct that embodies CSG’s key principles, including its expectations that suppliers will abide by human rights laws.
• Third Party Due Diligence Procedure: We endeavor to choose reputable business partners who conduct their business with high ethical standards. CSG conducts a thirdparty vendor review process and will add applicable questions to evaluate third-parties’ hiring and employment practices.
To ensure an increased level of understanding of the risks of Modern Slavery in our supply chains and our business and to aid our employees in identifying “red flag” situations, CSG requires that certain employees take training on Modern Slavery annually.
This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes CSG’s slavery and human trafficking statement for the financial year ending December 31, 2019.
President and Chief Executive Officer
Date: 26 May 2021