Modern Slavery Act
WPP Brands (UK) Limited
Modern Slavery Statement 2022
The following statement has been prepared in fulfilment of WPP plc (“WPP”) and its subsidiaries obligations under the Modern Slavery Act 2015. This includes WPP Brands (UK) Limited, which is a wholly owned subsidiary of WPP plc, the world’s largest communications services group. It operates as distinct brands including VMLY&R London, Burson Cohn & Wolfe, GCI Health, Landor and Penn Schoen and its principal activities are in providing advertising, marketing, product visualisation, public relations, branding and identity consultancy and design services primarily in the UK and Europe. We employ approximately 755 people, mainly working in offices located in the London area and approximately 41 people working in offices located in Dubai. This statement covers the financial year 2022 and describes our commitment and steps taken to mitigate modern slavery in our business and supply chain.
WPP is the creative transformation company. We use the power of creativity to build better futures for our people, planet, clients and communities through an integrated offer of communications, experience, commerce and technology. We offer capabilities in advertising, branding and identity, content, media investment, public relations and public affairs, and healthcare.
Respect for human rights is a fundamental principle for WPP and we do not tolerate any form of modern slavery or human trafficking in any part of our business. As a member of the United Nations Global Compact, we remain committed to embedding its ten principles for human rights, labour, environment and anti-corruption in our business and report progress against its 10 principles annually.
We know that modern slavery exists in almost every country in the world. An estimated 28 million people were in forced labour in 2021, according to the latest Global Estimates of Modern Slavery. Around the world, modern slavery risk (both forced labour and forced marriage) has increased over the last five years as armed conflict, climate change and the Covid-19 pandemic have disrupted education and employment and driven a rise in forced migration and extreme poverty.
We recognise the important role that our business has to play in combatting exploitative labour practices from our operations and supply chain.
The work we do for our clients reaches billions of people and has the power to shift perception and change behaviour at scale.
We support our clients to create brands with purpose and to integrate sustainability into their strategies, communications and marketing as they focus on translating targets into tangible change.
GroupM, WPP’s media investment agency, places over $60 billion of advertising in the media each year. To ensure that our influence is positive, GroupM is a member of Global Alliance for Responsible Media (GARM), a cross-industry initiative established by the World Federation of Advertisers to address the challenge of harmful content on digital media platforms and its monetization via advertising.
We also provide pro bono creative services to organisations working on human rights, health, education, arts and the environment, and negotiate free media space for charity campaigns, enabling them to reach a wide audience. Find out more information about our business here.
WPP and our agencies employ 115,000 people in over 100 countries across the globe and work with clients including 307 of the Fortune Global 500. WPP is headquartered in London and is listed on the London Stock Exchange and NYSE. Following a desk-based risk assessment of WPP’s direct operations we have noted that WPP has a physical presence and business operations regions at ‘high risk’ of modern slavery1. However, we consider the risk of our direct employees – as skilled professionals within the advertising, marketing and communications services sector – being victims of modern slavery is low.
OUR SUPPLY CHAIN
WPP is committed to creating a sustainable, ethical and diverse network of business-enabling suppliers. Due to the organisational structure of the business and wide range of services on offer, we have a complex and dynamic supply chain ecosystem to manage. We work with more than -68,000 parent companies across our supply network. Our suppliers fall into two main categories: those providing goods and services used to run our companies – such as IT and telecommunications, travel, facilities management, people services, professional services and real estate; and those used in client work – such as advertising & marketing services, production & media.
We are continually assessing supply chain risk based on country, industry sector, categories of goods and services, and individual suppliers. This is combined with a pre-engagement supplier due diligence questionnaire covering governance, compliance, sustainability, human rights and labour standards. Within the category assessment, we consider several high-risk factors linked to human capital, especially the recruitment and employment of low-skilled labour, migrant labour and contractors. We note that in 2022 the service sector, including transport and hospitality, accounted for the largest share of total adult forced labour exploitation – almost one third of the total (ref: Global Estimates of Modern Slavery, ILO, Walk Free and IOM, 2022).
In 2020, WPP began an extensive procurement transformation programme to enhance and improve our procurement ecosystem and infrastructure and as a result, optimise how we buy. [We have concluded the roll out of a modern spend analytics tool across all our WPP markets] and we continue to standardise and enhance numerous processes and systems, including those around supply risk management, procurement policy compliance, contract lifecycle management (CLM) and supplier onboarding and supplier relationship management (SRM). The programme will ultimately facilitate full life-cycle mapping and traceability across WPP's Tier 1 supplier network. The transformation programme is being led by our Chief Financial Officer and Chief Procurement Officer, and with the support from WPP’s Global Sustainability team will implement new controls and processes that are critical to a robust and responsible sourcing programme, whilst also providing support through regular policy training.
In 2023, we will commence the human rights due diligence exercise. The results will provide further visibility and transparency within our Tier 1 suppliers and help us further refine our risk assessment methodology. Work will also continue to standardise and enhance processes and systems relating to supply risk management, procurement policy compliance, contract lifecycle management and supplier onboarding and supplier relationship management.
DUE DILIGENCE IN OUR SUPPLY NETWORK
Our expectations of suppliers are set out in the WPP Supplier Code of Conduct and are based on the WPP Business Code of Conduct which applies to all our employees.
Contracted suppliers are required to sign the WPP Business Code of Conduct (Supplier Version), confirming they will comply with our standards or adequately demonstrate to WPP that they have the equivalent standards in place within their own business.
These standards include requirements relating to human rights, including modern slavery issues (such as child, forced or bonded labour), as well as labour practices (such as anti-harassment and discrimination, and health and safety), social impacts (such as anti-bribery and corruption) and other sustainability issues.
Our Code of Conduct requires our suppliers to apply similar standards to companies within their own supply chains, including diversity and social responsibility in their cultures, behaviours and attitudes.
In addition to signing up to our Code of Conduct, WPP suppliers are also required to complete an on boarding questionnaire which includes specific questions pertaining to modern slavery practices.
WPP also includes a “right-to-audit” provision in the supplier documentation and / or standard terms and conditions of contract. Our global Supplier Agreement includes a clause relating to modern slavery compliance. WPP reserves the right to terminate its contract with any supplier found to breach or fail to comply with, any legislation relating to modern slavery.
We do not tolerate any form of modern slavery or human trafficking in any part of our business. WPP is committed to tackling the risk of modern slavery from our supply chain and operations at a global scale.
As a member of the United Nations Global Compact, WPP views this as an essential component of our obligations to support the basic human rights of our people and their families, including the right to fair conditions of work, freedom from forced labour and child labour. We outline this commitment and set clear ethical standards for our people and companies through our policy framework.
Our Business Code of Conduct outlines how we are committed to acting ethically in all aspects of our business and to maintaining the highest standards of honesty and integrity. We specifically reference the Modern Slavery Act to highlight how seriously we take this issue. All our people are required to uphold our Business Code of Conduct, which is available in multiple languages. The principles of the Code are embedded in our training courses and workshops and our senior managers are required to certify compliance with the Code on an annual basis.
Our Business Code of Conduct – Supplier Version sets out our expectations of suppliers and is based on the WPP Code that applies to all our companies and people. The supplier version includes requirements for labour practices (such as anti-harassment and discrimination, and health and safety), human rights (including no child, forced or bonded labour), and social impacts (such as anti-bribery and corruption) as well as other sustainability issues. It is available in nine languages. WPP’s code of Conduct is set within a wider ethical framework, which includes our Human Rights Policy.
Our Human Rights policy reflects international standards and principles including the International Bill of Human Rights, the UN’s Guiding Principles on Business and Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and the Children’s Rights and Business Principles. In addition, our Sustainability Policy, updated in 2022 and approved by the Board on an annual basis, outlines our positive contribution to society and the environment underpinned by our responsibility to respect human rights. We also introduced a new Environment Policy in 2022 to reflect our climate commitments.
Our Procurement Policy outlines a clear procedure for responsible procurement. This includes the provision that, wherever possible, our companies should use centrally negotiated contracts with approved suppliers for commonly purchased goods and services. Regardless, anyone who buys goods and services in any WPP company should consider sustainability risks and criteria to determine whether suppliers are fit for purpose.
Our talent policies set out our core principles for responsible recruitment and people management as part of our responsibility to treat our employees with dignity and respect. As such, we are a living wage employer accredited by the Living Wage Foundation. This means that WPP, the parent company, and all our UK companies pay no less than the voluntary living wage to our people and all on-site contractors such as cleaning, security and catering staff in the UK. This exceeds the UK’s statutory national living wage.
WHERE WE ARE NOW
- WPP is a dynamic group with ever-evolving business operations and we recognise that there are always improvements that can be made to the way we work. To ensure that our policies are kept up-to-date and compliant with international and national regulatory frameworks we conduct regular reviews. In January 2022 we updated our sustainability policy, which is reviewed and approved by the Board on an annual basis.
- The application of our policies and procedures is monitored within each company and by the internal audit, legal, business integrity and risk and controls functions. Breaches are investigated by our legal and business integrity teams and, where appropriate, external advisors.
We have established governance processes and policies to help us manage human rights risks, including modern slavery, consistently across the Company. We have established governance processes and policies to help us manage human rights risks, including modern slavery, consistently across the Company.
Our Board-level Sustainability Committee has responsibility for reviewing and considering WPP’s Modern Slavery Statement and sustainability-related policies, including the Company’s Human Rights Position Statement, for approval by the Board. Our policy framework and training set clear ethical standards for our people and agencies. We want to embed a culture of integrity and transparency where our people make the right decisions automatically and instinctively. The WPP Code of Business Conduct applies to everyone at WPP. It sets out our responsibilities to our people, partners and shareholders to act ethically, legally and with integrity. Senior managers in all our agencies and our businesses are asked to sign a copy of the WPP Code of Business Conduct each year to confirm they will comply with its principles.
INSTITUTE OF BUSINESS ETHICS
WPP is a member of the Institute of Business Ethics (IBE) and considers it an important partner and support for the approach that the Company takes to business integrity, sustainability and ethics. As set out more fully in the Risk Governance Framework on page 86 and Business Integrity Programme on page 87 of our 2022 Annual Report, we want to champion and facilitate a culture where our people feel that acting with honesty and integrity is an expected metric for success, and this is also the IBE’s ethos. The IBE shares knowledge and good practice as well as advice on the development and embedding of relevant policies through networking events, regular publications and training sessions, research and benchmarking reports. The IBE is a registered charity funded by corporate and individual donations.
Our people can report concerns or suspected cases of misconduct confidentially (and, if they wish, anonymously) through our independently managed Right to Speak facility, which is overseen by our Business Integrity team and is available via phone or email in local languages. We publicise the facility in induction packs, on our intranet and external website, in offices, in the WPP Policy Book and via our mandatory ethics training. Our people can also speak directly to our business integrity team who receive a number of reports through emails, calls, texts and in-person appointments.
RISK IMPACT FROM WHISTLEBLOWER REPORTS 2022
All whistleblower reports received by the Group Chief Counsel and General Counsel, Corporate Risk, which includes all Right to Speak reports, are handled in line with WPP’s Whistleblowing and Investigations Protocols and logged, investigated and tracked through to a conclusion including any remediation or follow-up actions that might be required.
Reports are also analysed for risk impact and root causes. Learnings generated from this analysis are converted into recommendations including for training sessions, workshops and practical resources by WPP’s business integrity team and implemented together with the support and input of the Risk Committees. Recommended remediation can also include disciplinary action, changes to systems, controls and processes or wider review and monitoring for a particular time period.
The nature of each report, action taken and outcome is reported to the Audit Committee and the approach and process are reviewed by the auditors.
WPP is committed to providing a safe and confidential way for people with genuine concerns to raise them, and to do so without fear of reprisals. WPP does not tolerate any retaliatory behaviour against individuals reporting concerns and is equally committed to preserving the anonymity of an individual who makes a report and does not wish to have their identity revealed. The consequences of misconduct or retaliation range from individual performance management, training for a business or an office and one-on-one training or coaching for an individual through to staff relocation and staff dismissal.
WHERE WE ARE NOW
In 2022, a total of 372 reports were received from whistleblowers. All reports were followed up, investigated where appropriate by our business integrity team, and reported to the Audit Committee. None of these reports was linked to concerns of human rights or modern slavery. The most commonly raised concerns were about respect in the workplace and protection of WPP’s assets.
In line with the Australian Modern Slavery Act 2018, WPP AUNZ has outlined its own modern slavery risk assessment process in its third Modern Slavery Statement. The Statement addresses the Act’s mandatory reporting criteria, including the continued identification of modern slavery risks in its operations and supply chains and actions undertaken to address and mitigate these risks. For more information, read their Modern Slavery Statement available here.
In 2022, WPP AUNZ joined other corporate organisations in Australia in working towards reconciliation through the development of our first WPP ‘Reflect’ Reconciliation Action Plan (RAP), which outlines our total commitment towards a more diverse, equitable and inclusive future - with reconciliation at the heart of our ambitions. The plan, which has been formally endorsed by Reconciliation Australia, pays respect to the rich culture of Aboriginal and Torres Strait Islander peoples. It enables us to deepen our understanding of our sphere of influence and the unique contribution we can make to lead progress across the five dimensions of reconciliation: race relations; equality and equity; institutional integrity; unity; and historical acceptance. In 2023, we are developing the next stage of the WPP Reconciliation Plan.
TRAINING AND AWARENESS
All of our people (including freelancers working for more than four weeks) are required to complete our online ethics training, How We Behave, promptly upon joining and then on an annual basis thereafter. Topics covered include diversity, human rights, anti-bribery and corruption, conflicts of interest and avoiding misleading work. WPP has also issued guidance and training materials on modern slavery for our businesses to communicate to relevant people in their operations, such as HR Directors. The training covers the basic principles of the Modern Slavery Act 2015 and explains what modern slavery encompasses, how to assess risk in different aspects of our business and supply chain, our key policies, and our remediation process.
WPP is committed to working with other businesses and governments to act against modern slavery. In the UK, we are a member of the Business Against Slavery Forum (BASF), which is convened by the UK Home Office. Recognising that advertising production includes suppliers from high-risk sectors (such as support services such as catering, security and construction) we have joined the TV Industry and Human 9Rights Forum (TVIHRF) as an observing party. The TVIHRF are committed to identifying and tackling exploitation in collaboration with the broadcasting and production industry more broadly. We are exploring how to extend collaboration and apply learnings from the TVIHRF working groups to the advertising production industry.
WHERE WE ARE NOW
• For the training period ending in 2022, more than 130,000 employees, freelancers and contractors completed our mandatory online ethics training.
• In 2022, we commenced a refresh our ethics training, including an update to the sustainability module which covers human rights and modern slavery. This activity will be finalised in 2023.
• In 2022, we began a review of procurement and supplier onboarding documentation, which was completed in 2023. Following this review, refreshed mandatory Modern Slavery and Human Rights training was launched for and completed by the Global Procurement team. New team members will complete the training as part of their induction.
In 2021 we stated that:
Progress to date:
Identifying and managing the risk of modern slavery
In 2020, we began an extensive transformation programme to enhance and improve our procurement ecosystem and infrastructure and, as a result, optimise how we buy.
In 2022 as part of this transformation we will conduct human rights due diligence in high-risk procurement categories that are managed centrally by our global procurement team.
In 2022, we concluded the roll out of a modern spend analytics tool across the majority of WPP markets.
During 2022 the procurement team went through a transformation programme; there are now clearly defined category teams working towards in depth analysis of the supplier landscape with a view to completing that review in 2023.
In 2023, we will commence the human rights due diligence exercise. The results will provide further visibility and transparency within our Tier 1 suppliers and help us further refine our risk assessment methodology.
Work will also continue to standardise and enhance processes and systems relating to supply risk management, procurement policy compliance, contract lifecycle management and supplier onboarding and supplier relationship management.
Awareness and training
In 2022, we will launch a refresher training module on Modern Slavery and Human Rights for the Global Procurement team and refresh our ethics training, including an update to the sustainability module which covers human rights and modern
In 2022, we commenced a review of procurement and supplier onboarding documentation.
Review completed in 2023 with refreshed mandatory Modern Slavery and Human Rights training and guidance launched and completed by the global procurement team.
Right to speak: In 2021, we appointed a new Right to Speak supplier and refreshed all Right to Speak literature and communications. We received 494 whistleblower reports,
Right to speak: In 2022, we reviewed and followed up concerns received through our Right to Speak facility. We received a total of 372 whistleblower
reports, none of
Ongoing monitoring: We will continue to address concerns received from stakeholders.
none of which identified modern slavery.
which identified modern slavery.
Approved by the Board on 17 May 2023
Chief Executive Officer