Modern Slavery

Working with our suppliers to affect positive change in the world

February 2021 Introduction

ITV plc and our subsidiaries are approach. There were lower risks in committed to identifying, addressing terms of fewer productions, fewer and preventing modern slavery in events and less international travel. our operations and supply chains However, there were higher risks to in a manner that puts concerns for individuals such as freelancers, potential victims at the centre. We self-employed workers and workers know that modern slavery is at the in supply chains, whose vulnerability extreme end of a spectrum of labour to exploitation and poor labour rights issues and that we need to practices increased. address labour issues well before they reach the threshold of modern slavery. This is our fifth modern slavery statement in which we set out the Our plans to address modern slavery steps we have taken during the in 2020 altered as a result of the 2020 financial year in support of Covid-19 pandemic, which changed this commitment. some of the risks we were facing and required us to reprioritise our Our structure, business & supply chains

ITV produces, distributes and drama, comedy and children’s We also distribute finished ITV generates revenue directly from broadcasts television programmes programmes via our channels and programmes and formats consumers through subscription video in the UK, Europe, the US and in on demand through platforms such worldwide through licensees. on demand (SVOD) on BritBox, the ITV a number of other countries. We as the ITV Hub and BritBox. Our Global Distribution business Hub+, competitions, live events and are headquartered in the UK, with sells finished tapes of scripted attractions, games apps, merchandise significant operations in the US, ITV Studios’ main business is and non-scripted programmes to and pay per view events, driving Netherlands, Australia, France creating, producing and distributing international broadcasters. Our value from consumers’ increasing and Germany. The company was TV programmes for international Global Entertainment business willingness to engage with our brands. formed through mergers of regional broadcasters and video on demand sells TV formats, such as The Voice, broadcast licence-holders and has platform buyers. In 2020, we made internationally and commercialises since expanded both organically and 8,400 hours of original content the IP in ancillary categories. For through acquisitions of production, through 55 labels in 13 different example, we enhance our offering distribution and digital content territories making scripted and to consumers through live events, businesses. We have been growing non-scripted programmes through merchandise and set tour attractions internationally since 2012. ITV Studios subsidiaries in the such as those of Coronation Street Netherlands, France, Germany, and Emmerdale. In the UK, ITV operates the largest Denmark, Norway, Finland, Australia, commercial family of channels. We Sweden, Italy and the US, as well as broadcast and commission news, other territories. sport, documentaries, entertainment, Our colleagues Our supply chains and partnerships TV production includes supply ITV also enters into licences with Our colleagues include permanent and Our broadcast operations focus chains for clothing, equipment, third parties (licensees) for the use fixed-term employees, freelancers on getting programmes to air and props, set construction materials, of ITV’s intellectual property for the (mainly in TV production) and people ensuring technical compliance for vehicles and support services such creation, production and distribution working at ITV on behalf of our them. Our main supply chains for as catering, cleaning, security, driving of consumer products by the licensees suppliers, including those in cleaning, broadcasting include suppliers of IT and construction. We know that on their own account. maintenance and catering. support, data centres, transmission some of these sectors are higher and distribution partners, software risk for modern slavery and labour As of December 2020, we employed and technology contractors. Of these, exploitation and, alongside other 6,566 people globally as full-time we have previously identified IT broadcasters through the TV Industry equivalent employees, 4,486 people support operations based in India as a and Human Rights Forum, we are in the UK and a further 2,080 people possible risk. We engage closely with improving our understanding of the across US, Netherlands, France, our supplier and in 2017 and 2018 we extent of these risks in our industry. Germany, Italy, Finland, Norway, undertook site visits to the operations Many of the support services are Denmark, Sweden, Australia, Israel and to assure ourselves that labour rights provided through companies that Hong Kong. were being respected. specialise in supporting TV production, although there are occasions where production companies will need to find local non-specialist suppliers to meet their needs. Policies in relation to slavery & human trafficking

Our operations disciplinary processes and speaking updated annually by the Living Wage developing a new Work Experience All our policies flow from ITV’s Code up. Each business area throughout Foundation, which is higher than the policy to drive greater consistency of Conduct, which states that, “It our global operations has a dedicated Government’s National Minimum across the organisation and ensure is our intention only to contract Human Resources team to provide Wage and National Living Wage rates. that anyone on an internship or with suppliers and other associated continuous support and guidance on We have also standardised all our traineeship is paid a living wage. parties who can satisfy our standards all these policies. We further reviewed agreements so that anyone employed This is due to launch in March 2021. or pass our checks with regards to these guidelines as a result of the or contracted by ITV via a third-party labour and welfare conditions, anti- United Kingdom leaving the EU on organisation will receive the Living slavery, anti-bribery, the prevention 31 December 2020. Wage. The Living Wage is a route to of tax evasion and/or facilitation of encouraging social mobility and access tax evasion, information and cyber Since 2014, ITV has been accredited to the industry, particularly in higher security, health and safety and by the Living Wage Foundation as cost of living locations. We do annual environmental management or who a voluntary Living Wage employer checks across key suppliers to ensure have given a commitment to achieve in the UK. This means that we pay that increases in rates are applied. these standards within an all colleagues (permanent and agreed time-frame.” fixed term employees including In 2020, we revised the Right to Work apprentices, freelancers, contractors guidelines and trained the resourcing Supporting this, we have policies on and agency workers) as a minimum, team on changes to requirements holidays, sick pay, working conditions, the hourly rate set independently and and evidence needed. We are also Speaking up up. They are also required to adopt employment without fear of penalty. In 2020, we developed a new Speaking the inclusion of anti-modern slavery No worker should be charged fees or Up framework in light of the increased precedent clauses and general costs for recruitment or be required regulatory focus on whistleblowing warranties in contracts with suppliers to lodge deposits, identity or travel and the ongoing difficulties which the and business partners. documents. If potential victims are Covid-19 pandemic has presented with found, the Code of Conduct requires traditional face-to-face exchanges as a Suppliers suppliers to prioritise their safety. We channel for raising concerns. In 2020 we developed a new Supplier expect suppliers to notify ITV and work Code of Conduct which sets out the together to remediate any incidents of Production companies expectations that we have of our modern slavery. Where we have direct control of a suppliers, including in relation to production company or a majority human rights and labour. Suppliers are Implementation of our Supplier stake, we require them to adopt our required to take steps to understand Code of Conduct is supported by a policies and procedures including in and address the risk of modern slavery revised Third-Party Risk Management relation to modern slavery. This occurring in their operations and framework. includes adopting ITV’s Code of supply chains. This includes ensuring Conduct, which has requirements that workers are not illegal, forced, on pay, harassment, discrimination, involuntary, bonded or exploited diversity, health, safety and speaking and are free to terminate their Due diligence processes

In relation to slavery & human trafficking in our business and supply chains

Approach to risk management The Modern Slavery Steering Group, questions are answered and evaluated. In 2020 we revised our Third-Party Risk Across ITV, business divisions own the comprising senior representatives Questions cover a broad range of risk Management framework to improve management of their risks and are across multiple relevant functions, domains including modern slavery. the processes to help identify and responsible for: conducts an annual modern slavery manage modern slavery risks. risk assessment across the group. The ITV’s standard terms of engagement • Identifying and reporting local risks process identifies key risks, highlights with suppliers require them to: mitigating factors and potential gaps • Maintaining risk registers and in control. Different business areas business continuity plans where • Comply with all relevant laws, develop action plans and review including modern slavery legislation; appropriate them with an external human rights • Warrant that they have suitable • Implementing mitigating actions consultant. practices and procedures in place and controls to ensure that bribery, tax evasion, Supplier due diligence human trafficking and modern Business divisions are supported Our centralised procurement slavery does not take place in their by Group Functions, which include function supports all ITV’s UK Group Risk, Legal and Compliance, operations and operates a list of organisations or their supply chains; Health and Safety, Procurement, pre-approved suppliers. All new • Notify ITV if they become aware of Human Resources, and Workplace supplier engagements with a any violations; and Services. Identified risks are assessed value over £50,000 or where risk • Allow ITV to audit them to ensure and reported in line with ITV’s Risk is considered high are assessed to that they are complying with Management framework. ensure appropriate pre-qualification modern slavery laws. Key stages in the Third Party Risk Management process

Renewals & re-negotiations should initiate the start of the process again Where issues are identified, it may be ITV’s commissioning requirements We have trained all our production understanding of inherent risk factors necessary for ITV to terminate the stipulate that production partners leadership teams on this approach, for different types of production. engagement and our standard terms must pay, as a minimum, the Living called Leading Risk, and are planning include provisions that would allow Wage to eligible employees and to roll out Leading Risk 2.0 in 2021. The In 2020 we rolled out translated us to do so. However, we understand freelancers and the National Minimum programme is supported by a strong versions of the app across our that in certain cases summary Wage to volunteers, apprentices focus on reporting risks and concerns, international business. termination is likely to exacerbate the and trainees. As a minimum, our a culture of speaking up and a Duty of risk to already vulnerable workers and commissioning agreements include Care Charter for all those involved in It is mandatory for every new therefore in these circumstances we equivalent provisions on modern a production. Our Duty of Care focus production globally to complete an would seek to work with suppliers to slavery to those included in ITV’s is on physical and mental health, online Risk Notification Form which deliver compliant practice and use standard terms of engagement. giving us an important mechanism helps us to understand inherent risks termination as a last resort. for drawing attention to labour rights including risks related to modern Studios risks in content-making. We support slavery, among other issues and to Media and Entertainment For productions, our risk management production staff at all levels to raise prioritise those productions that need We know that the way we commission programme focuses on developing concerns and push back on aspects of additional support. The information television programmes can have the right behaviour and aims to productions that they are concerned triggers central support teams to look an impact on the labour practices ensure that those in the business about, including labour rights issues. into key issues. On a monthly basis of production companies and their making decisions on the ground are this information is reported to the treatment of suppliers. Therefore, empowered to understand, own and The positive risk environment within ITV Studios Board which decides on we use our commissioning process manage the risks in the making of ITV Studios facilitates similar cultures the suitability of the mitigations in to encourage best practice. Our pre- their content and are provided with among local production teams. place and the residual risk of medium commissioning processes include the support and expertise to enable Everyone on a production in the UK is and high-risk productions. Due to the due diligence around payment of the them to achieve this. This allows us to asked to download and use a reporting COVID -19 pandemic, there was very Living Wage and checks to identify understand whether our policies and app (the airsweb AVA app) to flag little production travel for most of any higher risk commissions and good practices are truly embedded incidents and concerns, which they can 2020. suppliers. Where increased risk is and implemented. The focus is on do anonymously. The data is shared identified further due diligence is encouraging openness and a culture transparently which is improving the undertaken by procurement and the of raising issues, gathering emerging communication between productions commissioning decision is escalated to themes and sharing lessons to drive and central risk teams. This enables the Commissioning Editor. continuous improvement. responses to issues before they become serious and leads to a better Business and supply chains

Where there is a risk of slavery and human trafficking taking place, and the steps we have taken to assess and manage that risk

At the beginning of 2020, the Modern TV productions Overall, the industry-wide research Despite the challenges, many ancillary Slavery Steering Group identified the Through ITV’s membership of the TV did not find evidence of systemic workers reported high levels of job following priority areas in which to Industry and Human Rights Forum, we hidden labour exploitation in satisfaction and reported good build ITV’s understanding of potential participated in collaborative research TV productions, in part because communications among those on set. slavery and trafficking risks: into the risks of modern slavery on TV subcontracting practices do not productions in the UK. The research involve lots of unknown workers on 1. TV productions focused in particular on ancillary sites as productions tend to use known 2. Merchandise and events workers who provide essential services and trusted individuals and industry 3. Workplace services to TV productions, such as cleaning, suppliers. However, the research did catering and security, but who are identify some other labour rights During the course of 2020, our often not seen as part of the crew. As issues including long working hours, focus shifted as a result of the part of this, we facilitated a deep-dive mental health challenges, a fear or COVID-19 pandemic, with many assessment of one of our productions reluctance to raise concerns and people not previously considered at and began work to understand precarious employment for ancillary risk of exploitation becoming more whether there were labour risks workers, who tend to be self-employed vulnerable as a result of losing work in our plans to cover the Euro or on zero hours contracts, whilst also and having to take on debt. This football championship. on low pay. applied particularly to freelancers, in support of whom ITV took significant steps. Case study - Dancing on Ice ITV facilitated a deep-dive labour rights assessment of Dancing on Ice, which is filmed in Hertfordshire. The assessment found high levels of engagement and willingness to talk, as well indications of strong relationships between production and crew. It identified a range of good practices by the production itself and by many of the subcontractors. As most of those interviewed had experience working for a variety of broadcasters, they were able to identify industry-wide challenges and issues, which contributed to the broader research work. For ancillary workers, this included under-resourcing of security, ensuring that mitigations identified in risk assessments are in place and ensuring that ancillary workers are valued and supported. We already operate an enhanced insight into our supply chains and report for suppliers based in higher facilitates enhanced due diligence on risk assessment and due diligence means that we source as much as risk jurisdictions; all high risk third parties. process for ITV Studios’ produced possible from UK suppliers, on which content that is made in a high-risk it is easier to conduct due diligence • Comply (and procure that all Workplace services jurisdiction. All productions are tracked into labour practices. In 2020, most associated persons comply) with ITV directly employs people to deliver through a central database so that events did not run so the risks were applicable laws (including modern workplace services which include we know the stage that productions significantly reduced. slavery laws); reception services, logistics and are at and their location. High risk mechanical & electrical at our hub locations are flagged to the Legal and ITV also enters into licences with • Have in place suitable procedures buildings in London, Leeds, Manchester Business Affairs team who proactively third parties (licensees) for the use and systems to ensure that modern and Preston, as well at the sites used contact the productions to ensure of ITV’s intellectual property for the slavery does not occur in the licensee’s for filming Coronation Street and that they have put the right modern creation, production and distribution business or in its supply chain; Emmerdale. We work with suppliers slavery checks in place. In addition, we of consumer products by the licensees for security and catering, mechanical encourage our productions to engage on their own account. Whilst these • Notify ITV if they become aware & electrical and cleaning services and suppliers from a pre-approved list. licensees are not suppliers as such of any violations; and understand that roles in these services and ITV does not typically have a are often at higher risk of poor labour Merchandise and events role in managing the creation and • Ensure that all subcontractors practices. Accordingly, we manage our ITV sources merchandise through manufacture of the products, for any comply with the provisions of the contractors closely, building strong third-party suppliers and licenses product licences with a value of over licence agreement. relationships with them and checking subcontractors to run events on £50k, the licensees are required to their employees’ terms and conditions our behalf. We work closely with our complete due diligence questionnaires, ITV has a right to audit compliance and levels of pay to ensure that all third-party suppliers of merchandise which include questions that seek with the licence agreement. In workers are paid at least the Real Living to ensure that their due diligence to identify where risks might be for addition, we have a manufacturers Wage. practices include attention to risks of modern slavery in terms of geography agreement as part of our standard modern slavery. and business activity. product licence agreement that also In 2020, workplace services suppliers requires licensee’s manufacturer(s) were particularly hard hit and we For events, we work through a ITV’s standard product licence terms to contractually confirm directly to worked hard to support them and small selection of trusted agencies, with licensees requires them to: ITV that they comply with all relevant their staff through the pandemic. The which have themselves been obligations in the licence agreement situation obliged us to cancel certain of through thorough due diligence. • Comply with all local laws relating to including those set out above. our contracts but we helped to cover We are working hard to increase the employment and working conditions the costs of redundancy for employees. sustainability of props and materials and adopt ethical business practices Under the new third party risk for events, which is driving better including requiring a positive audit management process, procurement In the case of our main office catering to implement an approach within an Supporting freelancers who had not previously worried about service we transferred two long- agreed timeframe) and 13 are yet to TV production and broadcasting income suddenly found themselves serving staff directly onto our payroll reply. We will prioritise engagement relies on engaging freelancers and without work. Recognising that our to provide a new trolley service. with non-repliers in 2021. subcontractors. Teams of people come industry relies on freelance staff together for the time it takes to make contracts, ITV worked hard to reduce We also contributed 50% of The workplace services team is also a programme and then they move the vulnerability of this freelancer redundancy costs to the staff of responsible for building refits and on to other programmes, sometimes population by: other contractors where we had to construction projects. The team with ITV and sometimes with other reduce headcount, despite no legal aims to source as many materials production companies. In the UK, we 1. Successfully lobbying the obligation to do so. We are committed as possible from the UK in order to work with approximately 2,000-2,300 government to include freelancers in to supporting the wellbeing of reduce the carbon footprint and freelancers at any one time who are national support schemes; they were these staff where we can. recognising this provides additional mainly involved in the production and included by early April. opportunities for enhanced due broadcast of our TV programmes. The As well as managing our own buildings, diligence. For construction projects, freelance nature of engagement in 2. Identifying a particular issue for ITV uses a number of sites managed the tender process involves questions the TV industry can be both a benefit freelancers paid through PAYE who, by other landlords. In 2020, we wrote about modern slavery and checks to workers, in terms of flexibility and as a result of bureaucratic oversight, to 39 of these landlords to ask them on main contractors to understand a challenge, due to the unpredictable were not eligible for support. We about their modern slavery policies their commitment and willingness nature of assignments. worked with industry peers to lobby and statements. In total, 24 replied to address risks. In 2021, we aim to the Government directly to address to say they had measures in places, improve our monitoring of modern In 2020, the UK’s lockdown in the problem and established ITV 2 replied to say they did not have slavery risks in construction. response to COVID-19 shut down as a conduit to ensure furlough pay measures (and we have asked them productions and many freelancers reached this particular population of workers. 3. In October 2020 ITV supported the the Department for Culture Media COVID-19 communications launch of the Film and TV Charity’s and Sport used for other creative ITV took an early decision to send Whole Picture Programme, a 2-year industries. as many people home from the programme backed by Mind to office as possible before the official improve the mental health and In our UK operations, only Approved lockdown commenced in March 2020. wellbeing of freelancers working in Engagers can book freelancers. To We established a steering group with TV and Film. The initiative provides become an Approved Engager a representatives from key departments toolkits, training guides and resources person must complete mandatory and circulated an FAQ document as well as enhanced professional and training which includes content on quickly to colleagues. We also took peer support. labour rights and the importance an early decision to stop filming on of the Living Wage. All Approved Coronation Street and Emmerdale. 4. Getting people back into Engagers must complete annual Our human resources teams provided employment by getting TV refresher training. In 2021 we will regular communications focused productions up and running as introduce a digital application for on wellbeing and practical help quickly as possible by developing a contracting freelancers which will throughout 2020 and continued code and set of practices to ensure require the Approved Engager’s to meet quarterly with our trade a COVID-safe working environment; mandatory confirmation that the unions to keep them up to date we negotiated the protocol with rate being paid is in line with the with our actions. industry stakeholders, managed to Real Living Wage. get productions going again relatively quickly compared to other sectors and established a template that Training about slavery & human trafficking

Regular training Our Human Resources teams receive Additional training in 2020 Across the business there is annual training from an employment law ITV engaged an external expert mandatory online training which firm four times a year, which includes on modern slavery who provided references modern slavery and modern slavery updates. We also tailored briefings to the Modern Speaking up, among other aspects, provide regular communications to Slavery Steering Group and to the and reminds colleagues of the policies all Approved Engagers to ensure that procurement team at the start of the in place. This helps us ensure that they understand good labour practices year. This helped to shape ITV’s overall the highest standards of safety are and risks around modern slavery. approach to addressing modern maintained and that ethical and good slavery. judgement is applied when making decisions. Measuring our performance

Progress on commitments made in 2019 statement Measuring our performance

Raising concerns both our people’s ability to raise • Employee Assistance Programme employee networks which provides An important mechanism for tracking concerns and ITV’s open culture. The • Talking to Human Resources other avenues for people to raise our effectiveness is through grievance revised policy and processes are due • Raising an issue with a member of labour rights concerns. These include channels and there are a range of ways to be implemented in the UK and the management board The Ambassador Network of 77 that people can raise concerns at ITV. internationally in Q1 of 2021. The • Raising a formal grievance colleagues across ITV who represent Our Speaking Up process is available improvements include, amongst other • ITV’s Ambassador Network each and every department in ITV, for all workers to access should they things, the appointment of Safecall, The Women’s Network, ITV Able, ITV have any concerns about labour rights an independent third party, to provide In 2020 we introduced a questionnaire Embrace, ITV Pride and ITV Balance. practices. It applies to workers beyond a confidential Speaking Up telephone for leavers to gather further insights We encourage suppliers to raise direct employees and to those outside hotline and web-based reporting tool into the working experience at ITV. concerns with us, either through the UK. We are explicit in our Code of and proposals for fuller and more their ITV contact or via the Speaking Conduct and relevant policies that meaningful reporting on Speaking Up Beyond Speaking Up we have Up channels. In particular, we expect reprisals or victimisation of anyone concerns to the Management Board collective agreements with colleagues suppliers to notify ITV and work who raises concerns will not be and Audit and Risk Committee. in certain areas of ITV and we consult together to remediate any incidents tolerated. with the Broadcasting Entertainment of modern slavery, as set out in our In addition to the Speaking Up Communications and Theatre Union Supplier Code of Conduct. In 2020, the Audit and Risk Committee policy and the engagement survey, (BECTU), Unite and the National Union In 2020, we did not identify any undertook its annual review of colleagues can speak up through a of Journalists (NUJ). We see good incidents of modern slavery in our ITV’s Speaking up framework and variety of mechanisms including: relationships with trade unions as operations and supply chains. policy and was pleased with the an important mechanism for people proposed improvements, which, • Informal conversations with to raise concerns about their labour when implemented, will enhance managers and ITV’s Talking rights. Internally we have a group of Performance programme This statement has been approved by the Board of Directors of ITV plc on 26 February 2020.

Carolyn McCall Chief Executive

This statement relates to the ITV plc Group, including the following key subsidiaries:

ITV Breakfast Limited ITV Breakfast Broadcasting Limited ITV Broadcasting Limited ITV Consumer Limited ITV Digital Channels Limited ITV Studios Global Distribution Ltd ITV Rights Limited ITV Services Limited ITV Studios Limited ITV 2 Limited SDN Limited Useful Resources

Standards and Social Purpose Goals itvplc.com/socialpurpose

Speaking Up Policy itvplc.com/investors/governance/policies

Child Safeguarding Policy ITV’s Child Safeguarding Policy

Duty of Care Charter itvplc.com/investors/governance

Environmental Goals itvplc.com/socialpurpose/reducing-environmental-impact

Anti-Bribery Policy itvplc.com/socialpurpose/downloads

Contact procurement@itv.com