Exposure Group Anti-Slavery Statement

Introduction from the leadership team

We are committed to deploying practices to combat slavery and human trafficking. We oppose slavery and human trafficking in all its forms and make this statement to set out the steps we have taken to ensure that there is no slavery or human trafficking in our business or in our supply chains.

About us

Our structure

We are a provider of communications and marketing services. We are part of the Exposure Group and our ultimate parent company is Exposure Holdings Limited, which has its head offices in the UK. The number of employees employed by the Group varies but normally stands at approximately 175-200. The Group operates in the United Kingdom, the United States and France.

Our Group has a global annual turnover of £34,738,396 (for the year ended 31st December 2017).

Our business

Our business is organised into several business units, which have different types of expertise in the marketing and communications sector. The Group includes the businesses which trade as:

Our supply chains

Our supply chains include sub-contractors of marketing and digital services (including but not limited to influencer marketers, media partners, event producers, content producers and venue owners) and professional service providers (including but not limited to our auditors, law firms and IT consultants).

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due diligence processes for slavery and human trafficking

We believe the risk-profile of our particular business sector is low but we require our business teams to identify and assess potential risk areas in our supply chains to mitigate the risk of slavery and human trafficking occurring in our supply chains and to monitor potential risk areas in our supply chains.

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a supply chain compliance programme. This includes requiring our suppliers to a) provide contractual commitments that they will comply with applicable anti-slavery and human trafficking laws; and b) adhere to our Group Anti-slavery Policy.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we intend to implement training for our staff.

Our effectiveness in combating slavery and human trafficking

We also intend to consider developing key performance indicators (KPIs) to measure how effective we have been at ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains.

This statement is made in connection with section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 31st December 2017.

Exposure Group Anti-Slavery Policy

  1. Policy statement

    1. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

    2. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

    3. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

    4. This policy does not form part of any employee's contract of employment and we may amend it at any time.

  2. Responsibility for the policy

    1. The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

    2. The People and Culture, Finance and Legal Teams have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

    3. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate training on it and the issue of modern slavery in supply chains.

    4. You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to our People and Culture or Legal Teams.

  3. Compliance with the policy

    1. You must ensure that you read, understand and comply with this policy.

    2. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

    3. You must notify your manager or the People and Culture Team as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

    4. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains of any supplier tier at the earliest possible stage.

    5. If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or the People and Culture Team as soon as possible.

    6. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or the People and Culture Team.

    7. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the People and Culture Team immediately.

  4. Communication and awareness of this policy

    1. Training on this policy, and on the risk our business faces from modern slavery in its supply chains will be provided as necessary.

    2. Our zero-tolerance approach to modern slavery in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them (i.e. immediately upon their being established as a new supplier on our systems) and reinforced as appropriate thereafter.

  5. Breaches of this policy

    1. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

    2. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.