Dentsu International Limited (“dentsu international”) is a subsidiary of Dentsu Japan Inc and is the London based holding company for the dentsu business which specialises in providing media, digital and creative services. This business includes Dentsu London Limited, Merkle Marketing Limited, and their associated UK based subsidiaries and brands (together “dentsu”). Dentsu is headquartered in London, with local offices in Manchester, Leeds, Edinburgh, Newcastle and Stafford.
Dentsu International 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 dentsu. These policies apply in full to dentsu.
Dentsu International recognises the importance of aligning its business goals with the needs of society. That is why dentsu 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 dentsu takes very seriously. Dentsu is committed to conducting business with integrity and to the highest ethical standards, respecting human rights and protecting the interests of both dentsu employees and society.
As such, dentsu 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. Dentsu 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, dentsu 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
Dentsu 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 international global policies. These policies set out dentsu’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 policies that incorporate the values and objectives of the Act are as follows:
- The Global Code of Conduct – dentsu 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 dentsu’s commitment to continuously improve supply chain performance by integrating supply
- chain best practices into its operations and ensure suppliers are aligned with dentsu company values and principles and comply with all applicable laws and regulations, including the Act.
- Global HR Policy – This states dentsu’s commitment to uphold fair employment practices and observe 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 Speak Up 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 DENTSU TO COMPLY WITH THE ACT:
Supplier due diligence
As part of the updated dentsu 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 dentsu only engages with those suppliers who share and are fully aligned with its values and principles.
Due to its large number of suppliers, dentsu 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, dentsu intends to undertake a more detailed review of dentsu’s existing supply chain to further enhance compliance with the Act and extend the scope of the relevant risk assessment. Dentsu will also look to enhance the internal training of the UK business in relation to the Act.
Supplier adherence to the act
Dentsu’s standard supplier agreement templates now include modern slavery and human trafficking warranties and undertakings. Pursuant to these terms, dentsu makes it incumbent upon its suppliers to respect and comply with all applicable laws, including the Act, and dentsu 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 dentsu.
Dentsu’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. Dentsu’s CEO has also communicated to dentsu’s senior management team and to all staff within its UK subsidiaries and their respective trading divisions about the need to be vigilant about dentsu’s obligations under the Act
when procuring goods and services. Dentsu’s CEO and senior management take their responsibilities under the Act seriously.
The dentsu HR induction process has been amended to highlight the obligations under the Act to all new joiners.
Responsibility for compliance with our policies
Dentsu’s senior management team have the overall responsibility for dentsu’s compliance with the Act. Dentsu’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.
Dentsu's effectiveness in combatting modern slavery and human trafficking
The effectiveness of the steps taken by dentsu to ensure that modern slavery and human trafficking is not taking place in any part of dentsu’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 dentsu 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 dentsu business.
As part of dentsu’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 International Ltd Board of Directors and constitutes dentsu’s modern slavery and human trafficking statement up to the date of publication of this Statement.