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:
• 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.
