UK Modern Slavery Act Statement
This statement has been produced in compliance with the requirements of section 54(1) of the Modern Slavery Act 2015. It sets out our stance on tackling modern slavery and reducing the risk of modern slavery and human trafficking in our business and extended supply chain. This report is submitted by WeWork International Limited on behalf of itself and all of its subsidiaries with operations in the UK (together “WeWork”). It also references the operations and policies of WeWork Companies LLC and its affiliates - the parent company of WeWork International Limited - which are designed to mitigate the risk of modern slavery in our global business.
Reflecting this, the following statement sets out:
- The procedures WeWork currently follows to mitigate the risk of slavery or human trafficking in our own business and our supply chain, and
- The work we intend to carry out in the coming year and beyond to further strengthen these processes.
Community is at the heart of our mission. We are driven by the goal to create a world where people work to make a life, not just a living. And the only way to achieve this is together. We are dedicated to redefining success measured by personal fulfillment, and not just by financial gain. People, community and our values are at the heart of everything we do because we know that when we work together we can achieve great things.
Entrepreneurs, creatives, small and large businesses alike call our innovative workspaces home, each a member in the WeWork world, with access to a global community. Community is our catalyst. Based on the concept of offering space as a service, we currently operate 625 office space locations across 33 countries and 127 cities, with more than 600,000 memberships. Through our extended WeWork network we now touch and have a positive impact on over one million people around the world. We intend to expand this community in the future. We continuously seek ways to empower our employees to support and connect with local communities, driving positive impact and change to improve the lives of our members, employees and those individuals involved in our wider operations.
We recognize that, as a global company, we have a responsibility to look after and protect the wellbeing and safety of those who work with us and for us. We are committed to working together effectively and being present for and supportive of each other: this commitment extends to our employees, our members, our suppliers and the communities in which we operate.
Our Core Values
WeWork’s mission is to make a life and not just a living. We want to create an environment where our members, guests, staff and suppliers feel safe, supported and in which they can thrive. Our core values enable us to create our life’s work, and they are:
We do what we love and are connected to something greater than ourselves.
We are creators, leaders, and self-starters. We try new things, we challenge convention, and we’re not afraid to fail.
We are genuine to our brand, mission, and values. We're not perfect, and we don't pretend to be. We are always honest and as transparent as we can be.
We never settle. We get things done and we get them done well. We are persistent and knock down walls – literally if we have to.
We are grateful for each other, our members, and to be part of this movement. We don't take success for granted. We’re happy to be alive.
We are in this together. This is a team effort. We always look out for one another. We have empathy, we know we're all human, and know we can’t do any of this alone.
Our commitment to identify and reduce the risks of modern slavery in our supply chain and our wider business operations is a natural and important extension of our mission and values. We have zero tolerance for any instances of forced or bonded labour or human trafficking in our supply chains.
During our on-boarding process, all of our employees are required to read and commit to a number of policies. Our Code of Ethics is fundamental to ensuring a safe and fair working environment for all of our people and it underlines the importance of open and honest communication. We have a global Corporate Social Responsibility policy which sets out how we engage responsibly with the world around us and sets the groundwork for empowering our people to create positive social impact and drive a number of related initiatives.
We are proud of the impact that we can have on our employees, members and wider communities through delivering our mission. We recognize that being able to do what you love is a privilege and, for many people across the world, is still far from being a reality. As we expand and our operations reach more people, we have a great opportunity to bring meaningful change and we will continue to include the eradication of modern slavery in our approach.
Our Commercial Relationships
Our determination to fight against modern slavery and human trafficking is strengthened by our desire to work only with businesses and individuals that support our mission and share our values. It is important to us to build lasting relationships with our suppliers and we continue to review and enhance our contracting procedures to ensure our business partners are fully aligned with our objectives.
We strive to take all reasonable and practical steps to ensure that our standards are being implemented throughout the businesses of our suppliers and that local legislation and regulations are complied with. We take a risk-based approach to our sourcing practices which means that we are moving towards a more bespoke and localised supplier vetting process throughout the regions in which we operate. We recognise that the nature of our operations means that we contract with some suppliers in industries which have a higher risk index than others for the potential for human trafficking and modern slavery. Examples within our business of these at-risk groups include cleaning providers and construction companies. Where we identify a supplier which we consider to be operating in an at-risk industry or location, we perform additional checks which may include site visits to check the working environment and the labour practices of that supplier.
An ongoing area of focus is our supplier vetting process. To ensure that we continue to innovate and improve our processes, we are investing in technology and industry expertise on supply chain management and we are promoting the importance of these objectives particularly in our procurement and sustainability teams, welcoming a number of specialists to our business. Going forward, sustainable supply chain management is a key focus of WeWork and we will keep on challenging ourselves to seek out solutions to identify as early as possible any incidence of modern slavery or any practice which could facilitate such abuses so that we can take action. We are also engaging in updating and improving our forms of contracts across our operations in EMEA to include robust modern slavery commitments.
Policies, Procedures & Training
Our Due Diligence Programme
We have established a global, risk-based due diligence programme which informs and guides all of our interactions with suppliers and potential business partners through regular engagement with stakeholders and collaboration with our regulatory and legal teams. Our global procurement policy sets out our approach to the purchasing of those materials, goods and services which are essential to the creation and operation of our communities. This policy sets out the mandatory process for engaging the suppliers who will work with WeWork and it sets out our standard for supplier verification, obtaining trade references and securing the contractual relationship. It aims to ensure that we work with reputable suppliers that share our values. To date, the focus of our due diligence programme has been on our own operations, direct suppliers, and business partners globally. When we consider whether to work with a prospective supplier or partner, the first step is to ensure that the supplier is reviewed in accordance with our Supplier Vetting Policy. In addition, we assess the jurisdiction, industry, and any government ties the supplier may maintain, among other key factors. This allows us to create a risk profile which will inform our decision as to whether we engage with the supplier. We are rolling out a global RFP process as standard to ensure we have a tailored approach for each of our sourcing areas. For example, we have recently tendered our facilities management offering for United Arab Emirates. Recognising that the key risks of this industry include migratory workers without union or health and safety protection, poor housing standards, and worker’s passports being taken away, we created a bespoke RFP to include self-declarations of the suppliers as to their approach on housing standards (number of people per room, number of bathroom facilities per employee) and their employee contract types and we requested that they provide us with confirmation of their employee policies and standards and their construction certifications.
When deemed appropriate, suppliers are required to undergo an additional review by our Global Compliance Team. This can occur where we have suppliers or partners operating in a country or industry with a higher risk index in a particular sector and also in the event that our standard diligence checks highlight areas of concern.
During our recent years of exponential growth and as our operations diversify, we have been learning rapidly about our supply chain. We will look to develop tailored training for those employees whose role involves sourcing goods and services. We continually assess the efficacy of our due diligence programme and we are committed to enhancing our current due diligence procedures to proactively identify, address, and track negative impacts at all stages of our supply chain. Moving forward, insights from our due diligence programmes and stakeholder feedback will continue to be integrated into our internal processes to help ensure that we have the appropriate policies and management systems in place to prevent, identify, and address potential modern slavery risks across our supply chain.
As part of our strategy to identify and mitigate risk in our supply chain, including modern slavery, we operate a range of policies and procedures within WeWork. All WeWork company employees are required to adhere to and comply with our code of ethics, anti-corruption, anti-money laundering, and sanctions policies. These policies are based on industry standard principles and they help us set clear expectations for our employees, suppliers, and other business partners, while also establishing a framework that helps us monitor compliance with our standards.
We also maintain policies that address discrimination, harassment, and general workplace conduct. Together, these resources play an integral role towards embedding our values throughout our business.
Our members live and breathe our community each day in our office spaces. In order to foster and maintain an environment of trust and collaboration we implement global and building specific house rules which help lay the groundwork for a convivial working space, and which we enforce in the event of non-compliance.
As part of our commitment to advance respect for modern working practices throughout our broader value chain, we are working to establish a supplier code of conduct (“Vendor Code of Conduct”) to enhance our existing supplier requirements. The Vendor Code of Conduct will apply to suppliers working on WeWork’s behalf and require them to take appropriate measures to ensure that no child labour or forced labour occurs at their place of production or operations. It will also place a responsibility upon our suppliers to ensure that any sub-contractors or suppliers they work with have appropriate practices and policies in place to mitigate the risk of modern day slavery and forced labour in their places of production or operations. The Vendor Code of Conduct will be fundamental to securing a global standard throughout our extended supply network and to increasing accountability.
Modern slavery can be challenging to detect and we recognise that our policies and programmes alone may not go far enough to prevent against the risk of all adverse impacts in our supply chain. For this reason, WeWork encourages employees to report any and all suspected violations of our values, code of ethics, policies or applicable law, including those violations that could arise within our supply chain. Authenticity is one of our key company values and through fostering an environment of openness, collaboration and community, we aim to empower all of our people to speak up and be heard. All employees are also encouraged to report issues confidentially and seek advice from their manager, the Global People Team, or the Legal Department.
In 2018, WeWork implemented a ‘Raising Concerns’ helpline to enable our employees and partners to report compliance and ethics concerns easily and, if needed, anonymously. The helpline is an important part of our culture of ethics and integrity and is operated by an independent and leading company who provide the facility 24/7, 365 days a year, in a number of languages. Information from reports are collated and shared with members of the Legal Compliance Department. All allegations of improper conduct received through the helpline are promptly and confidentially investigated.
Finally, as the company recognises that it takes courage for employees to come forward and share their concerns, our code of ethics includes a promise to never retaliate or permit retaliation against anyone who raises questions or concerns in good faith about company activities, including improper labour practices or concerns about our supply chain.
Training plays a fundamental role in our work to embed our core values and expectations around compliance. We have established formal training programmes for our employees and we continue to evaluate and review these programmes. These programmes help us to raise awareness of potential issues, to communicate our policies and standards, and to provide our employees with guidance on issues related to modern slavery. We require employees at all levels in the company to complete training in business ethics and workplace conduct courses.
Coupled with our whistleblowing helpline, in 2018 we also launched a “Compliance Captains” programme throughout the company to raise awareness and disseminate information on ethics and compliance matters. The programme provides for a two-way dialogue and allows us to ensure that we have eyes and ears on the ground throughout our global operations. We circulate a monthly newsletter to our Compliance Captains, reporting on developments, training opportunities, external events and asking for feedback.
Case Study: The Power of Community
We believe that every person should have the opportunity to create their life’s work. We have partnered with the International Rescue Committee (IRC) to help provide opportunities for meaningful employment and training to refugees around the world. In 2017 we piloted the refugee programme in New York, and began asking our network of member companies and the broader business community to join us in hiring refugees, or in offering their support, skills or networks to expand their opportunities. As part of this initiative we have launched the Skills for Work Programme, which partners refugees with WeWork employees to develop leadership skills, communication in the workplace and career planning. Going forward we will also engage with other charitable organisations such as the TENT Partnership for Refugees, and Breaking Barriers.
Supporting underserved and underrepresented people in our community
In support of our belief that every person should have the opportunity to create their life’s work, in March 2019, WeWork began a collaboration with Change Please to provide barista services in some of our buildings. Change Please initially took advantage of the growing demand for coffee in London, offering people experiencing homelessness all over the city the opportunity to train as baristas. The organisation provides people affected by homelessness with accommodation, training, and employment paying the Living Wage, in a variety of locations to support them to move forward. Since then, we have worked with Change Please to expand their footprint by implementing their baristas in new buildings we have opened in Manchester, Edinburgh, Cambridge and Birmingham. In South Africa, we collaborate with I Love Coffee, a social enterprise that employs and trains deaf young persons to become baristas – part of a movement that helps create a more accessible and independent future for the deaf community. Our ambition is to grow both these collaborations and to continue to explore new opportunities to support underserved or underrepresented groups.
Youth mentorship programme
With the strength of our membership network, we recognise where we can play a significant role in supporting young people, connecting them with members and unlocking their future career opportunities. Through our youth mentorship programme, we host career management workshops for young people in London, Paris and Berlin with our member companies. Mentees are coached by WeWork member companies, from a range of industries, including fintech, tech, and digital services. The goal is to offer opportunities for young people to network with WeWork’s member companies that they might not otherwise be exposed to and to offer career insight that mirrors the modern professional landscape. In 2019, we have invited over 200 young people onto our mentorship programme.
We want to be impactful and make a real difference to the lives of our employees, our members, our suppliers and all those touched by our operations. We are not afraid of taking action in the face of environmental and social problems: in 2018, we committed to going “meat-free” and we are working to eliminate single use plastic from all member and corporate locations. As a meat-free company, no company funds may be used to purchase meat products including beef, pork, and chicken at all company events and during work-related travel. As WeWork continues to expand, we are confident that these global environmental initiatives will positively impact our supply chain and the rights of workers around the world.
Assessment of Effectiveness in Preventing Modern Slavery
WeWork is a dynamic and fast-growing company with the intention and opportunity to have a significant positive impact on the communities that it touches. We know that we must be particularly alert to new risks and opportunities that will arise as a result of our operations and our expansion. This is a responsibility which we welcome and which we take seriously. We continue to invest in our approach, investing in new talent and new technology to allow us to reflect on, develop and enhance our strategy to combatting modern slavery and human trafficking in our wider business and supply chain. We want to be accountable and transparent about our future goals to improve our current practices. We set out below our commitments for the coming financial year.
Our Commitments for 2020
- Publish the Vendor Code of Conduct
- Review and enhance training for employees, particularly those involved in sourcing, to embed compliance standards, educate on the risks of modern slavery and empower them to speak out safely on any risk of other violations
- Strengthen our RFP process
We look forward to reporting on our progress in future modern slavery statements.
This statement has been approved by the Board of Directors of WeWork International Limited, who will review and update it on an annual basis or more often as we progress with the objectives set out in this statement.
Last updated on 25 November 2019.