his statement outlines the steps taken by HERE International B.V. and all of its direct and indirect subsidiaries in which HERE International B.V. owns a majority of the shares or exercises effective control (collectively, “HERE”) pursuant to section 54(1) of the Modern Slavery Act 2015 during the financial year ended on December 31, 2024 - to assess our susceptibility to modern slavery risks, review HERE’s due diligence and risk assessment practices, and to continue to ensure that modern slavery and human trafficking is not taking place in any of HERE’s supply chains, and in any part of our business.

The term "modern slavery" is used in this statement to describe a range of situations in which coercion, threats or deceptions are used to exploit individuals and undermine their freedom. These situations include, but are not limited to, slavery, servitude, forced marriage, forced labour, debt bondage, indentured labour, deceptive recruiting for labour and child labour. It also includes withholding of identification documents and human trafficking. 

Organisational structure and supply chains

HERE has been a pioneer in mapping and location technology for over 40 years. Today, HERE’s offerings are recognized as the most complete in the industry, powering location-based products and services for organizations and enterprises across the globe.

HERE’s unwavering commitment to environmental, social, and governance (“ESG”) principles remains at the core of our business ethos. These guiding principles shape our operations, drive our dedication towards customers, frame our interactions with suppliers, and reflect our responsibility to the world we share. We strive to exceed stakeholder expectations by minimizing our environmental footprint, investing in our communities and workforce, and upholding the highest ethical standards.

HERE upholds the highest ethical and social standards when conducting business operations and extends the same expectation to our customers, partners, and suppliers. We have policies and procedures in place aimed at promoting sustainability and compliance throughout our entire supply chain.

Our policies

Human Rights and Modern Slavery

At HERE, we are committed to integrating respect for all international human rights into our global operations and across our value chain. In 2024, we updated our global Human Rights Policy that outlines this commitment. In practice, this commitment means that HERE: 

• Operates to the standard of international human rights law and applies these standards when local law falls short of international human rights standards or when there are no relevant national laws. Where local laws conflict, HERE aims to honor the principles of international human rights.
• Trains our employees on international human rights standards and what they mean in practice.
• Conducts self-assessments based on ESG factors to identify gaps and remedy known impacts.
• Assesses ESG factors across key suppliers within our supply chain, makes recommendations for remediation, as needed, and participates in HERE customers’ supplier audits.
• Recognizes the right to freedom of association and promotes the humane treatment and non-harassment of our employees and those in our supply chain.
• Commits to non-discrimination and respects the rights of individuals belonging to groups or populations which may be particularly vulnerable to adverse impacts, including indigenous people, national or ethnic, religious and linguistic minorities, children, LGBTQ+ people, people with disabilities, and migrant workers and their families.
• Believes women’s rights are human rights and commits to providing liberty, dignity, and equal rights, regardless of gender.
• Promotes the inclusion, diversity, and belonging of under-represented groups of people within our company and in society.
• Practices ethical recruiting by hiring workers lawfully and in a fair and transparent manner that respects human rights.
• Works with relevant public and private security entities to protect HERE facilities and employees in a manner that supports and reinforces respect for human rights.
• Expects suppliers who do business with HERE to uphold human rights and business ethics practices.
• Prohibits the hiring of child labour. The minimum age for full-time employment with HERE is the higher of 15 years old or the legal minimum age for employment under applicable law. HERE further prohibits the hiring of individuals that are under 18 for positions in which hazardous work is required.
• Adheres to fair working hours, wages and benefits in alignment with local law.
• Prohibits any form of forced labour including bonded labour, prison labour, indentured labour and slave labour, or human trafficking.
• Respects land, forest and water rights in the communities in which HERE operates and commits to no forced evictions.
• Complies with all applicable sanctions.
• Adopts and publishes an annual Modern Slavery Statement.

Code of Conduct

HERE has a Code of Conduct in place, which guides everyone at HERE in making decisions that reflect our high ethical business standards by explaining the expected behavior and responsibilities of all HERE personnel as well as those of our affiliates, suppliers and partners. Our Code of Conduct provides clear and simple directions and covers all our business activities. This includes an obligation to report any potential violations and participate / cooperate in any investigations. 

The Code of Conduct applies to all employees at HERE, and to all directors, officers and employees at other business ventures in which we own a majority of shares or exercises effective control. HERE requires the principles expressed in the Code of Conduct to be followed by all those with whom HERE does business.

HERE also makes a good faith effort to implement the Code of Conduct (or something similar) in operating entities in which we invest, but do not own a majority stake. 

HERE’s Code of Conduct contains specific sections on fair labour conditions and employment. There are explicit warnings to look out for failures to observe labour laws (e.g. child labour, workplace safety, compulsory labour, etc.). It also contains a section on human rights. 

We have a strict no-retaliation policy against anyone who raises concerns of any kind. 

All employees receive mandatory Code of Conduct training and – depending on their business unit and function – a variety of other trainings applicable to their job responsibilities.

Supplier Code of Conduct

At HERE, we endeavour to extend our human rights standards to every company in our supply chain through our Supplier Code of Conduct and HERE’s Sustainable Procurement program. HERE reviews its potential exposure to human rights risks and breaches annually, which includes a standardized questionnaire to suppliers as well as a risk assessment of HERE supply chain against ESG factors by using a software solution.

Supplier management is a crucial part of our Sustainability program. HERE continues the push to implement corporate responsibility and ethical practices into every aspect of its supply chain, including the many external vendors, suppliers and service providers with which we collaborate and do business. HERE has committed to only working with vendors who share our high ethical standards when it comes to abiding by the laws and policies of the countries in which HERE operates. To monitor our suppliers’ performance with HERE’s expectations, we established a supplier audit program in 2019. In June 2023 we updated our Supplier Code of Conduct.

Our Supplier Code of Conduct sets down our expectation for our suppliers to at least meet the applicable laws and regulations in the countries in which we and they operate. We encourage suppliers to go beyond legal compliance by committing to meet relevant international standards (such as those from the International Labour Organization or applicable United Nations conventions) and to commit to continuous improvement. HERE suppliers shall conduct their business in accordance with the highest ethical standards and all applicable laws and require the same compliance throughout their entire supply chain.

HERE suppliers shall not use forced, bonded, compulsory, or imprisoned labour, or allow such practices in their supply chains.

The Supplier Code of Conduct contains specific sections and guidance on ensuring safe methods to report abuses as well as labour and human rights aspects such as a prohibition on using forced, bonded, or compulsory labour. HERE also expressly prohibit the use of child labour and human trafficking by our suppliers and has a commitment to allowing free association.

Flow-through to sub-suppliers and business partners

An important part of upholding our Supplier Code of Conduct is ensuring that our suppliers only do business with others that adhere to the same standards of ethics and compliance as HERE expects of our suppliers. 

Each HERE supplier shall have a program in place to conduct due diligence, monitor and control their own business partners to help ensure that they all meet expectations consistent with those set out in the Supplier Code of Conduct. HERE suppliers may not engage in any activity prohibited by the Supplier Code of Conduct by knowingly employing – or failing to impose appropriate corrective action, up to and including termination, upon – a subcontractor or supplier who performs the prohibited activity on behalf of such HERE supplier. HERE suppliers shall never engage a sub-supplier to undertake any activity that would be prohibited by the Supplier Code of Conduct or applicable law if undertaken by HERE suppliers or their staff.

Reporting Mechanisms

At HERE, we have implemented mechanisms through which HERE employees, suppliers, and other stakeholders can report concerns to HERE regarding modern slavery and any other compliance issue (including anonymously). HERE’s Speak Up Program provides various channels for confidentially reporting concerns, enabling swift review and action by HERE. These channels include the HERE Ethics Hotline, a reporting platform available 24/7, 365 days a year, that supports both confidential and anonymous reporting.

HERE investigates and remediates all credible allegations and concerns related to legal, compliance, human rights and other violations in the company and in HERE’s supply chain. HERE is committed to remediating the findings of any such investigation. Investigations are undertaken by, or with the oversight of, the HERE Ethics and Compliance Committee, which reports to senior management.

Violations and Discipline

For HERE employees any violation of the Code of Conduct, other HERE Policies and Procedures or applicable law, will result in effective corrective action or employee discipline when necessary. Disciplinary measures, up to and including termination of employment, will be applied subject to local law.

For suppliers, any violation of the Supplier Code of Conduct or applicable labour or human rights rules results in corrective action. The appropriate action in a particular case depends on the nature and severity of the violation and the circumstances surrounding the situation. Failure to comply with the Supplier Code of Conduct and applicable laws and regulations may result in the termination of the supplier's agreement with HERE and referral of the matter to local authorities.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes HERE’s slavery and human trafficking statement for the financial year ended on December 31, 2024.

Approved by the management board of HERE International B.V. in Amsterdam, the Netherlands on May 26, 2025.

Signed

By: Mr. M.G. Nefkens                             By: Mr. W.L.M. Buskermolen
Title: CEO / Managing Director            Title: CHRO / Managing Director           

View a copy of our 2023 statement

View a copy of our 2022 statement