Statement under the UK Modern Slavery Act for financial year ending 31 December 2022
S4Capital presents its annual statement pursuant to the provisions of section 54 of the Modern Slavery Act 2015 (the Act) for the year ended 31 December 2022. Both S4Capital and its group companies will be collectively referred to as ‘S4Capital’ for the purposes of this statement.
S4Capital is committed to upholding the principles of the Act, taking measures to ensure that modern slavery in the form of slavery, servitude, forced or compulsory labour and human trafficking is not taking place in any pert of S4Capital’s business or in those of our clients and suppliers.
At S4Capital, we take seriously our responsibility to conduct business in an ethical way. Media.Monks, a S4Capital subsidiary, has been a member of the United Nations Global Compact since 2012. The United Nations Global Compact is a strategic policy initiative for businesses that are committed to aligning their operations and strategies with 10 universally accepted principles, including in the areas of human rights and employment. We are also committed to upholding the Universal Declaration of Human Rights and the core conventions of the International Labour Organisation.
S4Capital is a tech-led, new age/new era digital advertising, marketing and technology services business, providing bespoke content, data analysis, digital media planning and digital transformation and technology services on a global, multi-national, regional and local basis. S4Capital, and the majority of the clients it provides services to, are truly global businesses. At the date of this statement, S4Capital has approximately 8,900 people in 32 countries with approximately 70% of revenue across the Americas, 20% across Europe, the Middle East and Africa and 10% across Asia-Pacific. S4Capital plc is the ultimate parent company of the S4Capital Group, which includes Media.Monks, and is headquartered in London, England. S4Capital is led by a highly experienced Board of Directors, details of which can be found here. Our General Counsel, Head of Compliance and Company Secretary is responsible for the day-to-day management our Compliance Programme, including drafting policies and procedures, training and monitoring and provides periodic reports to the Board and the Audit and Risk Committee.
Policies and Code of Conduct
We have several group-wide policies in place that are relevant to modern slavery and continually review, refine and develop our policies.
- Conduct of Conduct - Our code of conduct sets out the clear expectation of us as a company and explains the principles that underpin our ethical standards and is applicable to all S4Capital employees and contract workers in all locations globally, [including third parties working on behalf or representing S4Capital]. Our code of conduct is available here.
- Supplier Code of Conduct - Our supplier code of conduct, outlines our expectations of the standards we expect suppliers to meet, this includes regarding human rights issues such as child labour.
Speak up Policy - We encourage anyone, whether working for S4Capital or not, to speak up about misconduct, possible breaches of our Code of Conduct, or other company policies, including our Anti-Financial Crime Policy or procedures, and suspected violations of laws and regulations. More information on Speak Up is available here.
Supply Chain and Supplier Due Diligence
The nature of the services S4Capital provides offers limited opportunity for modern slavery and/or human trafficking practices. While this may be the case, S4Capital recognises it remains important to monitor its supply chains to help prevent and identify the risks of modern slavery.
S4Capital seeks to establish and improve its processes to:
- include additional enquiries in its procurement processes for goods, services and locations that are assessed as having a high risk of modern slavery or human trafficking, including an evaluation of any internal policies and procedures such suppliers have in place;
- better (i) identify, assess and monitor potential higher risk areas in our supply chains; and (ii) mitigate the risk of slavery and human trafficking occurring in its supply chains through enhanced contract term controls (to the extent appropriate and obtainable); and
- continue building relationships with known suppliers and ensure that expectations of business behavior are both clear and consistent.
Our commitment to help prevent and identify risks of modern slavery starts with S4Capital's board of directors. The S4Capital Audit and Risk Committee provides oversight on specific issues involving internal and external controls and compliance with legal and regulatory requirements, including compliance with our MSA Statement.
We monitor the effectiveness of our policies and processes and our relationships with suppliers and we regularly report to the S4Capital's board of directors, including material issues.
We continue to monitor our performance against the following in order to gauge how effective we are in dealing with modern slavery and human trafficking risks in our business or suppliers:
- implementation of our MSA Statement;
- implementation of our Supplier Code of Conduct, which sets out our zero-tolerance approach to slavery and human trafficking and also helps to communicate a number of important related human rights expectations and is in the process of being rolled out to all of our suppliers;
- developing a system for supply chain identification, including, where appropriate, adding modern slavery and human trafficking enquiries and controls to our procurement policies (in accordance with our Supplier Code of Conduct);
- asking specific questions on modern slavery as part of our procurement processes;
- seeking to include protections relating to modern slavery in our terms with third parties for the supply of goods and services;
- implementing a reporting process on key performance indicators on an annual basis, including in relation to training and the roll-out of our Supplier Code of Conduct; and enhancing our compliance program to include regular training on modern slavery.
We will provide regular training as necessary to educate on the importance of implementing and enforcing effective systems to ensure slavery and human trafficking is not taking place in our supply chains. This will form part of a wider programme of compliance training for all relevant members of management and those in our procurement team, which takes place on a regular basis.
This Modern Slavery Statement 2022 was approved by the Board of Directors of S4Capital plc on 27 April 2023.
Sir Martin Sorrell
27 April 2023