Modern Slavery Act 2015 (Act) - Statement
Dentsu Aegis London Limited, and its subsidiaries and brands, specialise in providing media, digital and creative services. DAN is a subsidiary of Dentsu Aegis Network Ltd. DAN is headquartered in London, with local offices in Manchester, Leeds, Edinburgh, Newcastle and Stafford. Dentsu Aegis Network Ltd, which is DAN’s UK-based parent company and the global headquarters for the Dentsu Aegis Network companies, has a comprehensive set of global policies referred to in more detail below that, amongst other matters, encapsulate the obligations under the Act to prohibit modern slavery and human trafficking within DAN’s business.
DAN recognises the importance of aligning its business goals with the needs of society. That is why DAN strives to make a positive social impact by investing in the communities in which it operates, embracing diversity through culture and people practices, and being committed to doing business in an environmentally sustainable way. These actions are all part of a personal and collective responsibility DAN takes very seriously, and why being ‘responsible’ is one of DAN’s core business values. DAN is committed to conducting business with integrity and to the highest ethical standards, respecting human rights and protecting the interests of both DAN employees and society.
As such, DAN has zero tolerance of modern slavery and human trafficking and is committed to doing all it can to ensure no form of slavery or human trafficking exists within its supply chain. DAN expects the same from everyone it does business with and will not knowingly engage with any person or organisation suspected of being involved in modern slavery or human trafficking in any form.
As a media, digital and creative services provider, DAN procures services from both domestic and international suppliers across a diverse range of goods and services. Suppliers include but are not limited to:
• media partners;
• IT services and equipment providers;
• printing and production suppliers;
• photographic and other creative services suppliers;
• facilities management and office suppliers;
• catering suppliers; and
• travel services suppliers.
Policies and procedures
DAN is committed to work within applicable laws and as the Act is an integral part of the UK legal framework its requirements are reflected in the Dentsu Aegis Network Ltd global policies. These policies set out DAN’s commitment to comply with the Act and the expectations it imposes upon its supply chain and their respective procurement functions to ensure their own compliance with the Act.
The Dentsu Aegis Network Ltd global policies that incorporate the values and objectives of the Act are as follows:
• The Code of Conduct – DAN is committed to conducting business with honesty and integrity and upholding high standards to protect the interests of its employees, clients, shareholders, stakeholders and communities in which they work. All employees are required to behave consistently with the Code of Conduct.
• Supply Chain Policy – This states DAN’s commitment to continuously improve supply chain performance by integrating supply chain best practices into its operations and ensure suppliers are aligned with DAN company values and principles and comply with all applicable laws and regulations, including the Act.
• Global HR Policy – This states DAN’s commitment to uphold fair employment practices andobserve the laws that pertain to, among others, the prohibition of forced, compulsory and child labour and the laws relating to the elimination of any improper treatment or discrimination of employees.
• Global SpeakUp Process – This encourages employees to raise, in confidence, any concerns they may have about a suspected wrongdoing in the workplace which includes any concerns regarding the risk of modern slavery or human trafficking.
STEPS TAKEN BY DAN TO COMPLY WITH THE ACT:
Supplier due diligence
As part of the updated DAN supplier onboarding process, prospective suppliers are required to certify their compliance in relation to the requirements of the Act in a supplier questionnaire. This is to ensure that DAN only engages with those suppliers who share and are fully aligned with its values and principles.
Due to its large number of suppliers, DAN has undertaken a risk based approach and written to its top 100 suppliers in the UK advising them of the strict requirement to comply with the Act.
Prior to the issuance of the next Statement, DAN intends to undertake a more detailed review of DAN’s existing supply chain to further enhance compliance with the Act and extend the scope of the relevant risk assessment. DAN will also look to enhance the internal training of the UK business in relation to the Act.
Supplier adherence to the Act
DAN’s standard supplier agreement templates now include modern slavery and human trafficking warranties and undertakings. Pursuant to these terms, DAN makes it incumbent upon its suppliers to respect and comply with all applicable laws, including the Act, and DAN reserves the right to terminate its commercial partnership with any supplier who is found to be in breach of, or who fails to comply with the Act. This applies to both domestic and international suppliers contracting with DAN.
DAN’s key corporate functions such as UK procurement, CSR, legal, finance, compliance and human resources have all received guidance on the obligations under the Act. DAN’s CEO has also communicated to DAN’s senior management team and to all staff within its UK subsidiaries and their respective trading divisions about the need to be vigilant about DAN’s obligations under the Act when procuring goods and services. DAN’s CEO and senior management take their responsibilities under the Act seriously.
The DAN HR induction process has been amended to highlight the obligations under the Act to all new joiners.
Responsibility for compliance with our policies
DAN’s senior management team have the overall responsibility for DAN’s compliance with the Act. DAN’s key corporate functions such as UK procurement, CSR, legal, finance, compliance and human resources teams will keep under review all relevant business activities and practices to ensure compliance with the Act as well as communicate the responsibilities to stakeholders.
DAN’s effectiveness in combatting modern slavery and human trafficking
The effectiveness of the steps taken by DAN to ensure that modern slavery and human trafficking is not taking place in any part of DAN’s business and within its supply chain will be measured by the following key performance indicators (KPIs):
• number of instances of modern slavery and human trafficking identified as part of the DAN supplier due diligence process; and
• number of instances of reports being received from employees, the public or law enforcement agencies that modern slavery and human trafficking practices have been identified within the DAN business.
As part of DAN’s ongoing efforts to ensure there is no modern slavery or human trafficking in its supply chain, it intends to continue to review and monitor and, where necessary, enhance its systems, policies and procedures, as well as improve its training and communications about the Act across the business.
This statement is made in accordance with section 54(1) of the Act. This statement has been approved by the Dentsu Aegis Network Ltd Board of Directors and constitutes DAN’s modern slavery and human trafficking statement up to the date of publication of this Statement.