External assessment in the US, following allegations against one of its content moderation operations
PARIS, November 14, 2022
As previously announced, promptly following publication of the Forbes article about Teleperformance USA’s content moderation services in early August, Teleperformance’s senior management engaged the Group’s Global Audit Team to complete an audit of our US operations for a key content moderation client. The internal audit found no apparent child sexual abuse materials (“CSAM”) being used during Teleperformance’s employee onboarding or in Company-provided training programs and continuing education documents.
In addition to the internal audit that TP USA conducted, TP USA engaged a nationally-recognized consulting firm, working at the direction of Latham & Watkins LLP, outside counsel advising Teleperformance on this matter, to assess TP USA’s compliance with its contractual obligations to the client.
The external assessment included an analysis of TP USA’s contractual agreements with the client, meetings and discussions with TP USA personnel, including with TP USA functional leaders from Internal Audit, Information Technology and Information Security, Wellness, Talent Acquisition, Content Moderation, and others.
In addition, the external assessment included ten in-person and virtual focus groups with TP USA content moderation employees, including some interviews that were conducted during a three-day site visit to TP USA’s El Paso site, and dozens of follow-up discussions. The external assessment also consisted of a review and analysis of a voluminous set of TP USA documents, procedures, and policies.
None of the findings from the external assessment were inconsistent with the conclusions from TP USA’s internal audit that TP USA did not find CSAM content in Company-provided ongoing education materials or guidance documents.
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