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Modern Slavery Act Statement

 

The Company is part of the Interpublic Group (“IPG”) and IPG is one of the world’s largest

organisations of advertising and marketing services companies. IPG is committed to excellent

corporate governance and lawful and ethical behaviour is of paramount importance and critical

to its continued success. The IPG Code of Conduct and the IPG Supplier Code of Conduct

require all IPG entities and employees to operate with integrity and transparency in all

interactions with clients and other partners and places similar obligations upon its suppliers.

IPG is fully supportive of the laws introduced within the United Kingdom through the Modern

Slavery Act 2015 to combat slavery, forced or compulsory labour and the trafficking of persons

for any purpose (“Slavery and Human Trafficking”). IPG’s Human Rights Policy requires all

IPG agencies to commit strictly to the use of voluntary labour only and prohibits any form of

modern slavery.

This statement is made in respect of the Company’s financial year ending 31 December 2024

and is made in accordance with Section 54 of the Modern Slavery Act 2015 and outlines the

steps that IPG takes and intends to take to protect its businesses against all forms of Slavery

and Human Trafficking.

Copies of statements made by the Company in respect of previous financial years are made

available on request to the Company Secretary.

 

Business and Structure, Operations and Supply Chains

IPG’s ultimate parent company, The Interpublic Group of Companies, Inc., is listed on the New

York Stock Exchange.

 

As a global organisation, IPG’s suppliers worldwide include, without limitation, production and

design companies, IT and communications services including cloud, software and hardware

suppliers, advertising platforms, social media platforms, print services, property, office

cleaning, office supplies and equipment and facilities management services, including energy

suppliers, waste management services, couriers, transportation services, such as road

transportation, airlines and train companies, merchandise suppliers, and hospitality service

suppliers including hotel conference or venue providers, catering suppliers, professional

services such as auditors, actuaries, tax advisors, legal advisors, insurers, banks and talent

and recruitment agencies.

 

Given the nature of IPG’s business and the geographical location of its business and suppliers,

IPG does not consider that there is a significant risk of modern slavery within its supply chains

or its own businesses. The principal suppliers in our advertising business supply chain are

predominantly reputable companies providing ancillary services to our advertising and

marketing services for clients, such as, media owners, production companies, design

companies, editing and animation studios, record companies, musicians, photographers, and

also professional suppliers such as legal advisors, insurers, and talent agencies.

No instances of Slavery and Human Trafficking have been identified by IPG in its operations

or suppliers.

 

Relevant Policies

Doing business in an ethical and responsible manner is core to the manner in which IPG

operates and is captured within its global policies and procedures (which apply to all IPG owned entities) and, in particular, those referred to below which have been designed to help

to ensure that Slavery and Human Trafficking do not occur within any IPG entity’s operations

or any of their supply chains.

 

These policies are available on IPG’s public website:

Corporate Governance

 

IPG Code of Conduct

IPG Supplier Code of Conduct

Supplier Management Principles

IPG Human Rights Policy

Anti-Corruption Policies

Environmental Sustainability Policy

Interpublic Alertline

 

IPG requires all its suppliers, employees, agents and subcontractors to adhere to the IPG

Code of Conduct or the IPG Supplier Code of Conduct as appropriate while doing business

with or on behalf of any entity within IPG. The IPG Supplier Code of Conduct specifically

requires use of voluntary labour and prohibits slavery, servitude or the use of forced or

compulsory labour and human or labour trafficking and requires all suppliers to comply with

applicable laws. IPG communicates this Code and its requirements to relevant management,

employees and suppliers worldwide.

 

IPG is also a participant in the United Nations Global Compact whose labour principles

include:

 

Principle 3: business should uphold the freedom of association and the effective

recognition of the right to collective bargaining;

Principle 4: the elimination of all forms of forced and compulsory labour;

Principle 5: the effective abolition of child labour; and

Principle 6: the elimination of discrimination in respect of employment and occupation.

 

Other Actions Taken to Address Modern Slavery Risks

IPG sources its suppliers in a responsible manner under its Global Sourcing and Procurement

and Third-Party Supplier Due Diligence Guidelines and fully expects and requires its suppliers

to operate in full compliance with all applicable laws. Our standard terms of business attached

to our Purchase Orders, and our supplier contract templates include warranties that the

suppliers will comply with applicable laws including modern slavery laws. Under these terms,

a failure by a supplier to comply with applicable laws (including as they relate to Slavery and

Human Trafficking) would be a justifiable reason for such a relationship to be terminated.

When engaging suppliers, we ask them to complete a supplier questionnaire to confirm their

structure, shareholdings and their agreement that they comply with our policies and the IPG

Supplier Code of Conduct.

 

Risk control and assessment is a high priority for IPG and IPG carries out continuous reviews

to improve its effectiveness. IPG has introduced a new vendor on-boarding platform which

includes a modern slavery assessment for suppliers. The initial vendor request includes a

specific question on whether the supplier supplies services in the UK. If the supplier responds

yes to that request they are asked further basic questions about modern slavery compliance,

their own risk analysis of their supply chain and whether or not they have issued a modern

slavery statement. This platform was initially operated in the UK, USA and Canada and was rolled out to Australia, Singapore, India and The Philippines in July 2024. Its use is extending to China, Hong Kong, Taiwan and Japan in 2025.

As part of our robust compliance program to ensure we are conducting business with reputable

suppliers and service providers, we have also established a global third-party screening

solution using the Truth Technologies Sentinel Database. The screening is conducted on all

clients and suppliers when permissible by law. IPG also uses Bureau Van Dijk Orbis for

enhanced screening. Ongoing screening is conducted on new suppliers as part of the

onboarding procedures. The screening is conducted against the following criteria:

 

Named on an International or National Sanctions or Embargo List or Site, including

OFAC, UN, EU, UKHMT, SECO and DFAT (Global Sanctions Lists).

Listed on a Regulatory and/or Government Authority site, e.g. FINRA, USDOJ, SEC,

FBI, HKMA, RBI and INTERPOL (Global Enforcement and Warning Lists).

Politically Exposed Person (PEP) and direct family member or close business

associate of PEP (Global PEP Lists).

State Owned Entity, Enterprise or Company (SOE) and Members of the Board,

Chairman, Senior Executives (Global SOE Lists).

Reported in the reputable media as accused, questioned, investigated, arrested,

charged or convicted for crime (Global Negative Media Lists).

 

Due to what we perceive to be a low risk of modern slavery within our industry and due to our

rigorous on-boarding processes described above, we do not consider it necessary at this stage

to routinely audit our suppliers (or indeed their suppliers) to ensure that they are compliant

with modern slavery laws. However, we are prepared to do so should the need arise.

Compliance within the business is supported by a robust Internal Audit function which regularly

conducts audits of our agencies in all their areas of business and works closely with the

internal Legal Department to ensure compliance with all applicable laws and regulations. Most

key agencies are audited once every three years. However, where we believe there may be

an issue or concern in an agency, or where we consider an agency is operating in a high-risk

jurisdiction, or where an issue has been raised either formally or through the Interpublic

Alertline, then that agency will be subject to an enhanced audit or investigation, if necessary,

with third party auditors, external law firms or tax investigators.

The Interpublic Alertline allows our employees or other concerned parties to raise concerns

about any business conduct without fear of reprisal or retribution. The Alertline number is

included on Alertline posters in all our agencies across the world, especially those in higher

risk countries. It is also available on the IPG website and is brought to the attention of our

employees in our compliance training and details of the Alertline are included in our Supplier

Code of Conduct. The Alertline allows for any concerns to be raised anonymously and every

complaint or claim made on the Alertline is investigated.

IPG continues to build upon its robust compliance culture and seeks to maintain its high

standards. As part of its ongoing efforts to ensure there is no Slavery or Human Trafficking in

its supply chains IPG continues to review its supplier engagement policies, contractual

approaches and due diligence processes to continually monitor the risk of Slavery and Human

Trafficking. IPG regularly reviews its Supplier Code of Conduct and recent updates include

expanded statements on governance, sustainability, business diversity and reporting.

 

Training

IPG’s new hire Code of Conduct training is provided to all new employees globally and IPG

conducts general compliance and Code of Conduct training on a regular basis for all

employees. The risks of Modern Slavery are set out in the Code of Conduct.

On the basis that it remains our opinion that the risks of finding occurrences of modern slavery

are relatively low in our supply chain, we have, as yet, not carried out additional specific

modern slavery training for any of our agencies but this will be reviewed.

 

Remediation

If any instances of modern slavery were identified, through an audit or otherwise, we would

immediately investigate and if we found failings with the relevant supplier, we would terminate

the contract/s with that supplier, ensure that none of our businesses used that supplier in the

future and, where necessary, report the supplier to the appropriate authorities. No instances

of modern slavery have yet been found in our supply chains.

 

Assessing the Effectiveness of Actions Taken

We continue to regularly review our own policies and processes to ensure they remain up to

date and effective. The effectiveness of these processes will also be tested as part of our

Internal Audit function, which extends to all our agencies.

 

Other information

IPG is committed to its work around environmental, social and governance (ESG) initiatives

and to supporting the communities where our employees live and work.

IPG engages with NGOs around the world that align with our values and our principles on

donations are set out in the IPG Global Contributions Strategy and Policy.

IPG has been named on the Human Rights Campaign Foundation’s Equality Index for 15

consecutive years. In 2024, IPG was named to the Dow Jones Best-in-Class Indices North

America (formerly the Dow Jones Sustainability Index) for the fifth year, and to the Dow Jones

Best-in-Class Indices World for the first time, in recognition of its commitment to sustainable

business practices. IPG is also listed on the FTSE4Good Index and Disability IN’s “Best Places

to Work for Disability Inclusion,”. Since 2015, IPG has published sustainability reports utilising

the GRI framework and was the first US-based holding company to do so. IPG was also the

first in its sector globally to report using the Sustainability Accounting Standards Board

framework in 2020 and the first US-based advertising holding company to disclose in

accordance with the Task Force for Climate-related Financial Disclosures.

IPG also responds to CDP and the Corporate Sustainability Assessment and publishes an

annual Communication on Progress for the United Nations Global Compact referred to above.

IPG maps its work to the United Nations Sustainable Development Goals, and has focused

on SDG 6, access to water and sanitation. IPG has set three major climate goals which include

near-term science-based targets approved by the Science Based Targets Initiative, working

toward net zero by 2040, and achieving one hundred percent renewable electricity by 2030.

 

Approval

This statement was approved by the Board of Directors of the Company.

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