SUPPLY CHAIN TRANSPARENCY

YAHOO
UK MODERN SLAVERY ACT STATEMENT

INTRODUCTION

At Yahoo, we are committed to the highest standards of business conduct in our relationships with each other, our users, our stockholders and our customers, suppliers and partners. We recognize that servitude, slavery, forced labour (including debt bondage) and human trafficking (collectively, for the purposes of this statement, “Modern Slavery”) are a global issue and that no industry is immune. We will not tolerate any instances of Modern Slavery in our business operations, supply chain or the business operations of those we partner with.

This statement is made in accordance with the Modern Slavery Act 2015 for the financial year ending 31 December 2016 and sets out the steps that Yahoo has taken to prevent Modern Slavery in its business operations and supply chain. This statement also sets out some of the measures Yahoo intends to take, including reviewing our processes and policies.

BUSINESS AND SUPPLY CHAIN

Yahoo is a guide to digital information discovery, focused on informing, connecting, and entertaining our users through our search, communications, and digital content products. By creating highly personalized experiences, we help users discover the information that matters most to them around the world - on mobile or desktop. Our corporate headquarters is located in Sunnyvale, California in the United States. As a global technology company, we have office locations and data centers across the world.

Yahoo creates value for advertisers with a streamlined, simple advertising technology that leverages Yahoo’s data, content, and technology to connect advertisers with their target audiences. Advertisers can build their businesses through advertising to targeted audiences on Yahoo’s online properties and services and a distribution network of third-party entities who integrate Yahoo’s advertising offerings into their websites or other offerings. Yahoo’s revenue is generated principally from search and display advertising.

As an information and digital content delivery company, the majority of our procurement activities are related to the purchase from third party vendors of IT equipment, office related materials, and professional services.

Yahoo also has key agreements with various business partners in relation to search and advertising services, sales operations, technology and intellectual property licensing, and product development, promotion, and distribution.

POLICIES AND ACCOUNTABILITY

Yahoo is committed to ensuring that Yahoo employees and contractors (together “Yahoos”) undertake mandatory ethics and compliance training and follow the Yahoo Code of Ethics (the “Code”).

The Code applies to all Yahoos and provides the information necessary to help each Yahoo act with integrity and in compliance with the laws and regulations applicable to our worldwide operations.

Yahoos are aware of the Code and of the high standards expected of them and are encouraged to seek guidance when ethical issues arise. All Yahoos are encouraged to be vigilant and raise any concerns they may have of unethical behaviour. The Ethics and Compliance Office (“ECO”) is responsible for overseeing compliance with the Code and maintains multiple avenues through which employees or other concerned parties can report potential violations of the Code, applicable laws or regulations or other ethical or compliance issues, which includes: Yahoo’s 24-hour “Integrity Hotline”(Integrityline.yahoo.com), which is translated into 8 languages; and Yahoo’s ECO telephone and email service.

RISK ASSESSMENT AND PROCESSES FOR PREVENTING MODERN SLAVERY

As a result of the nature of our business operations we believe there to be a relatively low risk of instances of Modern Slavery in our business operations. However, Yahoo acknowledges that Modern Slavery is a global problem and that every industry is affected and every company needs to remain vigilant.

In our business relationships and procurement activities we take various steps through our contracts and agreements to prevent any complicity in Modern Slavery and seek to ensure that our suppliers and partners observe the same high standards that we expect of all Yahoos. The Code requires compliance with applicable laws and regulations, as well as outlines our ethical values and expectations of integrity. These requirements apply not only to Yahoos who make choices about who we partner with, but also to our partners by incorporating the Code in our business agreements, where possible. Yahoo also seeks to ensure the awareness of and compliance with the Code by our vendors. As part of the on-boarding process for vendors, we require, where possible, that they explicitly acknowledge receipt of and adherence to the Code.

We also seek to ensure that our procurement activities are further governed by Yahoo’s standard vendor terms & conditions, where possible, which require that vendors comply with applicable laws and regulations.

TRAINING

All Yahoos are required to take mandatory ethics and compliance training. The training, in part, reminds Yahoos of their requirement to act ethically and in compliance with the law while employed by Yahoo.

FURTHER STEPS AND LOOKING AHEAD

During the next financial year, Yahoo will diligently continue to review and, where necessary, update our contracts, policies and training programme, including a review of the Code and supplier and procurement policies. Yahoo will continue to remain vigilant to identify and mitigate the risk of Modern Slavery in its business and supply chains and in particular will continue to monitor its operations in higher risk jurisdictions.

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes Yahoo’s slavery and human trafficking statement for the financial year ended December 31, 2016. This statement has been approved by the board of directors of Yahoo! UK Services Limited.

Nigel Clarkson
Director
Yahoo! UK Services Limited

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