Dentsu International Limited (“dentsu”) is a subsidiary of Dentsu Group Inc and is the London based holding company for the dentsu business which specialises in providing media, customer experience management and creative services. This business includes Dentsu UK Limited, Merkle Marketing Limited, and their associated UK based subsidiaries and brands (together known as “dentsu UK”). Dentsu UK is headquartered in London, with local offices in Manchester, Leeds, Edinburgh, Newcastle and Stafford.
Dentsu 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 remains cognisant of the importance of aligning its business goals with the needs of society, and 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 remains committed to working within applicable laws and as the Act is an integral part of the UK legal framework its requirements are reflected in the dentsu 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.
- The Supplier Code of Conduct –is publicly available on the dentsu website and clearly states that dentsu’s suppliers must conduct their business with honesty and integrity, upholding dentsu’s high standards to protect their employees and workers.
- Supply Chain Policy – This reiterates 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 details 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 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.
The specific question related to the requirements of the Act was assigned the highest possible risk rating if a potentially noncompliant answer was submitted by any supplier. Risks were monitored and reviewed for all suppliers, new and existing, who completed the questionnaire in 2021; no modern slavery risks were identified during this process.
Using the information collected during this process, dentsu has undertaken a more detailed review of dentsu’s existing facilities supply chain to further enhance compliance with the Act and extend the scope of the relevant risk assessment.
SUPPLIER ADHERENCE TO THE ACT
Since 2019, dentsu’s standard supplier agreement templates have included modern slavery and human trafficking warranties and undertakings, which dentsu continues to review and strengthen where necessary. 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 also has a Supplier Code of Conduct which is publicly available on the dentsu website and clearly states that dentsu’s suppliers “must have zero tolerance of modern slavery and human trafficking and ensure that no form of modern slavery or human trafficking exists within their supply chain. This includes not engaging with any person or organisation suspected of being involved with, or using any form of, forced, bonded or compulsory labour.”
Dentsu’s key corporate functions such as UK facilities, procurement, Social Impact, legal, finance, compliance and human resources have all received guidance on the obligations under the Act. Further a programme of annual mandatory training has been put in place for all UK facilities and procurement staff covering modern slavery, dentsu Code of Conduct and how to Speak Up should they have concerns.
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 further updated to emphasise the obligations under the Act to all new joiners.
RESPONSIBILITY FOR COMPLIANCE WITH OUR POLICIES
Dentsu’s senior management team continue to have the overall responsibility for dentsu’s compliance with the Act. Senior leadership at market level are required to complete an annual certification confirming that the entities for which they are responsible do not use or facilitate, or procure goods and services from suppliers who use or facilitate, forced, indentured, bonded, slave or human trafficked labour or any type of involuntary labour.
Dentsu’s key corporate functions such as UK facilities, 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 continue to 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.
The activities and efforts described above reflect 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.
Global CEO, dentsu International