MODERN SLAVERY STATEMENT Under the Modern Slavery Act 2018 (Cth) for the 2020 Reporting Period THIS REPORT OUTLINES
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MODERN SLAVERY STATEMENT Under the Modern Slavery Act 2018 (Cth) For the 2020 Reporting Period THIS REPORT OUTLINES PART 1: BUSINESS OVERVIEW 1 PART 2: ADDRESSING MODERN SLAVERY 3 PART 3: STRUCTURE, OPERATIONS AND SUPPLY CHAINS 4 PART 4: RISKS OF MODERN SLAVERY PRACTICES 5 PART 5: ACTIONS TO ASSESS RISKS 8 PART 6: EFFECTIVENESS OF ACTIONS 10 PART 7: APPENDIX 11 WPP AUNZ Limited ACN 001 657 370 (“WPP AUNZ”) 1 Kent St, Millers Point NSW 2000 MODERN SLAVERY STATEMENT - UNDER THE MODERN SLAVERY ACT 2018 (CTH) 1 PART 1: BUSINESS OVERVIEW INTRODUCTION & EXECUTIVE SUMMARY WPP AUNZ is Australia and New Zealand’s leading creative transformation company and provides an integrated offer of advertising, marketing, media, public relations and communication services to its customers. WPP AUNZ is a majority-owned (61.5%) subsidiary of WPP plc, and WPP AUNZ is a reporting entity under the Modern Slavery Act was formerly known as STW Communications Group Limited before it 2018 (Cth) (the Act). WPP AUNZ’s first mandatory reporting period merged with the Australia and New Zealand assets of WPP plc in 2016. concluded on the 31 December 2020. This Statement is approved by the Board of WPP AUNZ Limited. WPP AUNZ BUSINESS OVERVIEW WPP AUNZ is the region’s largest advertising, marketing, media, public Ogilvy, VMLY&R, Wunderman Thompson, whiteGREY, Hogarth, BCW, relations and communication services provider, which offers end-to- Hill+Knowlton Strategies, Landor & Fitch and the media investment end solutions to drive creative and innovative customer interactions management brand, GroupM, comprising Mindshare, Mediacom, for its clients. Wavemaker, Essence and Xaxis. WPP AUNZ’s portfolio consists of over 60 brands across Australia, The portfolio also comprises local and regional brands such as Aleph, Ikon New Zealand and Asia. It includes global brands such as AKQA, Communications, Cannings, Buchanan, Phuel and The Brand Agency. BRAND SOLUTION PILLARS Each brand brings differentiated skills to deliver against four solutions pillars: Communications, Experience, Commerce and Technology. COMMUNICATIONS EXPERIENCE Advertising, branding UX, service design, and identity, content, websites, platform and media investment, public applications, voice and relations and public affairs, augmented reality. healthcare. COMMERCE TECHNOLOGY Retail experience, direct- Data management, to-customer platform and marketing technology, marketplace. consulting, systems and integration services. MODERN SLAVERY STATEMENT - UNDER THE MODERN SLAVERY ACT 2018 (CTH) 2 OPERATIONS It has also developed campus models – an operating model and WPP AUNZ has a local and global client network that includes structure that encourages deep collaboration between various co- financial institutions, private corporations, publicly listed located brands – in New Zealand, Adelaide, Perth and Brisbane. corporations, state entities, government departments and agencies and not-for-profits. CAMPUSES AND OFFICES The operating structure and footprint are summarised below. WPP The physical presence of WPP AUNZ’s direct operations (campuses and AUNZ has offices in most major cities in Australia, New Zealand and offices) and associated approximate employee numbers are as follows: across South East Asia. Australia 16 2,747 New Zealand 4 323 Indonesia 3 194 Singapore 2 91 Malaysia 2 52 Vietnam 1 2 Philippines 1 1 Thailand 1 1 Canada 29 United Kingdom 19 Hong Kong 7 Germany 4 USA 3 MODERN SLAVERY STATEMENT - UNDER THE MODERN SLAVERY ACT 2018 (CTH) 3 PART 2: ADDRESSING MODERN SLAVERY ADDRESSING THE RISKS OF MODERN SLAVERY DETAILED IN THIS STATEMENT WPP AUNZ accepts that, like all global businesses, the incidence of The preparation of this Statement has involved the completion of modern slavery deep within its supply chains is likely an unfortunate a number of key phases over a period of several months, which reality rather than a hypothetical concept. It is to be noted that the comprises WPP AUNZ’s overall modern slavery risk assessment process physical presence of WPP AUNZ in certain South East Asian jurisdictions during the mandatory reporting period. warrants particular attention, namely, the assessment of direct slavery risks associated with those operations, including through the provision THE KEY STAGES THAT HAVE BEEN UNDERTAKEN TO DATE of service industries such as cleaning and catering. AND ARE DETAILED IN THIS STATEMENT ARE: STATEMENT SUMMARY WPP AUNZ recognises that the efforts and measures described in this inaugural Statement are the early formal steps, since the introduction of Initial Risk Assessment Desktop Supplier Audit the Act, in its targeted efforts to carry out uniform and evidence-based modern slavery remediation. What is contained in this Statement is not suggested to be the achievement of an end goal in itself but rather a roadmap to build upon the positive initial steps that have been taken. In addition to meeting the specific legal reporting requirements under the Act, this Statement sets out WPP AUNZ’s methodology, key findings Supplier Self-Assessment Policy & Supplier and core future actions in relation to the issue of modern slavery risk Questionnaires Contracts Update identification and remediation. WPP AUNZ considers that being proactive in its efforts to address modern slavery in its supply chain and operations is part of its longstanding commitment to the promotion of sustainability. Such an approach is also wholly consistent with WPP AUNZ’s commitment to Internal Education & Training The Formation of a Modern building fairer, safer communities. Slavery Working Group and Consultation with Entities that WPP AUNZ Owns and Controls OUR PHYSICAL PRESENCE WPP AUNZ also recognises that its physical presence in certain countries within our region, which encompasses Australia, New Zealand and South East Asia, increases risks of modern slavery, including forced child labour, and is a further compelling factor to Assessment of impact Measuring Effectiveness ensure that it is adopting industry best practice in the assessment of COVID-19 Pandemic Framework on Supply chains and remediation of risks. The risks associated with the WPP AUNZ offices in high-risk countries is discussed throughout this Statement. BUILDING UPON THIS FOUNDATION, WPP AUNZ HAS IDENTIFIED THE FOLLOWING KEY AREAS ON WHICH IT OUR COMMITMENT INTENDS TO FOCUS ITS MODERN SLAVERY ASSESSMENT AND REMEDIATION EFFORTS IN THE SHORT TO MID-TERM FUTURE: WPP AUNZ is committed to a long-term effort to reduce and contribute to addressing modern slavery from its supply chains and operations at a global scale. To that end, it has engaged and been working closely with, subject matter experts on modern slavery over the course of 2019–2020. WPP AUNZ views this as an important component of its broader corporate social responsibility and human rights obligations. Detailed The identification and Post-survey assessment assessment of ‘low supplier of direct visibility’ areas of supply engagement international chain and operations presence with possible modern slavery risks MODERN SLAVERY STATEMENT - UNDER THE MODERN SLAVERY ACT 2018 (CTH) 4 PART 3: STRUCTURE, OPERATIONS & SUPPLY CHAIN REPORTING ENTITY IDENTIFY THE REPORTING ENTITY WPP AUNZ Limited | ACN 001 657 370 DESCRIBE THE REPORTING ENTITY’S STRUCTURE, OPERATIONS AND SUPPLY Please see Part 1 for an overview of the business of WPP AUNZ and the Appendix for a complete list of WPP AUNZ Limited subsidiaries. MODERN SLAVERY STATEMENT - UNDER THE MODERN SLAVERY ACT 2018 (CTH) 5 PART 4: RISKS OF MODERN SLAVERY PRACTICES DESCRIBE THE RISKS OF MODERN SLAVERY PRACTICES IN THE OPERATIONS AND SUPPLY CHAINS OF THE REPORTING ENTITY AND ANY ENTITIES IT OWNS AND CONTROLS WPP AUNZ’s processes for the identification of modern slavery risks has involved: Initial Risk Assessment Desktop Supplier Audit Supplier Self-Assessment Detailed assessment of direct Questionnaires international presence INITIAL RISK ASSESSMENT METHODOLOGY SUMMARY The key purpose of WPP AUNZ’s initial risk assessment was to identify sourced from Tier 1 suppliers to Tier 2 suppliers, Tier 2 suppliers to Tier the areas of likely greatest modern slavery risk in WPP AUNZ’s supply 3 suppliers, and so on, all the way to Tier 10 suppliers of the supply chain. This baseline exercise then formed the foundation for WPP AUNZ’s chain of WPP AUNZ’s suppliers by spend. subsequent focus in its ongoing due diligence and remediation activities. Once the supply chain was mapped in that manner, raw trade data Incorporating company spend data throughout global markets, WPP was compiled into Balanced Global Multi-Regional Input-Output (MRIO) AUNZ has utilised the proprietary technology of external consultants to tables to link the supply chain data from 190 countries and in relation to trace the economic inputs required to produce products and services 15,909 industry sectors. BALANCED GLOBAL MULTI-REGIONAL INPUT-OUTPUT (MRIO) THE MRIO WAS THEN EXAMINED AGAINST THEM IN RELATION TO INDUSTRY SECTORS: FOLLOWING INTERNATIONAL STANDARDS: The United Nations’ (UN) System of National Accounts The UN Guiding Principles for Business and Human Rights UN COMTRADE databases The Global Slavery Index Eurostat International Labour Organisation (ILO) Global Estimates of Modern Slavery The Institute of Developing Economies, Japan External Trade Organisation (IDE/JETRO) The United States’ Reports on International (IDE/JETRO); and Child Labour and Forced Labour Numerous National Agencies including the Australian Bureau of Statistics MODERN SLAVERY STATEMENT - UNDER THE