MODERN SLAVERY STATEMENT for the year ending 31st December 2018
This statement is made by the UK operations of Condé Nast International Limited pursuant to section 54(6) of the UK’s Modern Slavery Act 2015 (‘The Act’) for the financial year ending on 31st December 2018. It is an update to our statement for the financial year ending on 31st December 2017.
Condé Nast International (CNI) sets the benchmark for publishing excellence with leading print and digital brands including Vogue, Vanity Fair, GQ, Wired, and AD among others. Reaching more than 270 million consumers across Europe, the Middle East, Asia and Latin America, we are committed to delivering beautiful, influential content and brand experiences for individuals who demand to be inspired.
CNI is headquartered in London, but our print and digital brands are known around the world. In addition to publishing 30 brands, we run a licensing and restaurant division, the Condé Nast International Luxury Conference and several ventures in education. Committed to reinventing ourselves, we are constantly evaluating how we work across countries and brands and how we develop our products to expand our global leadership in the fashion, luxury and lifestyle spaces.
This statement is written to cover both the operations of Condé Nast International Limited (CNI) and each of its subsidiaries, including Conde Nast Publications Limited. References in this statement to CNI are references to the whole group.
We pride ourselves in respecting the individual no matter what gender, race, religion or orientation. We are committed to doing business in an ethical way, with honesty, integrity and humanity and we expect the same from our suppliers and their supply chains.
At CNI we take our social responsibility extremely seriously. We have a Code of Ethical Responsibility, emphasising how we work and recognising our commitment to obeying the laws in all areas in all countries in which we operate.
CNI has a zero-tolerance approach to slavery and human trafficking of any kind in our operations and supply chain and will take seriously any allegations that human rights are not properly respected.
During 2018 we further assessed the main areas of risk within our business and supply chain, the results of this assessment are summarized below:
The majority of the employees of CNI are office based and employed on service contracts in accordance with all local legislation and requirements. CNI offers salaries and benefits that meet or exceed regulatory requirements in the relevant jurisdictions. As a result, CNI believe that the risk of modern slavery occurring within its employee base is very low.
CNI regularly employs models and other contractors in all jurisdictions in which the group operates. In the past models in the fashion industry have been victims of abuse because of lack of regulation, power imbalances between models and photographers and/or publications.
CNI believe that models under the age of 18 are particularly at risk. To reduce the risk of abuse CNI introduced a comprehensive new Code of Conduct for working with models in January 2018. As part of this code of conduct specific restrictions apply to working with models under the age of 18, and we have an anonymous reporting procedure for any suspected violations. This code is available on our website:
CNI’s major revenue markets are UK, Italy, Germany, Spain and France. Given the controls in relation to our employees and contractors identified above, we consider our operations in these markets to be low risk. However, we will work to ensure that our approach to modern slavery issues, both in our business and our supply chain, are also implemented in these markets.
We procure goods and services from a wide range of providers, including freelance editorial suppliers, large and small technology suppliers, print and logistic suppliers, hospitality, catering, cleaning as well as other professional services. The majority of our suppliers are based in Europe and North America and do not present an obvious modern slavery risk.
Suppliers that are not directly under the control of CNI i.e. the sub-tier of suppliers in our supply chain are those most likely to present a modern slavery risks within our supply chain. We set out further details of our approach to modern slavery risks in our supply chain below.
CNI currently has the following policies and procedures already in place which we believe will help reduce the risk of modern slavery in our business and supply chain:
- Modern slavery
- Code of Conduct
- Code of Ethical Responsibility
Due Diligence & Procurement
We have established a Procurement Department who will have responsibility for identifying and mitigating any issues in the supply chain relating to The Act, going forward.
We are currently updating our procurement policies and procedures. As part of this process we are seeking to integrate the following:
- better assessment of the modern slavery risks presented by our core supply chains;
- incorporation of modern slavery diligence as part of our procurement policies and procedures; and
- incorporation of wording in supplier contracts to help address modern slavery risks.
We are in the process of introducing a new training programme to ensure that all staff are aware of and comply with the firm’s modern slavery policy and understand how to identify likely signs of modern slavery and how to report any suspicions. Enhanced training will be given to those persons who deal with suppliers and senior leadership in higher risk geographical regions to ensure they are able to fully implement CNI’s policies and values.
Key Performance Indicators
CNI is developing ways to assess the effectiveness of the steps it has taken to combat modern slavery. These are likely to include a review of existing suppliers to determine those which present the greatest risk of modern slavery whether because of the jurisdiction in which they are based or the services that they provide.
During 2019 we will continue to develop our procedures to address Modern Slavery Risks in our supply chain. Our aim is for this to include:
- a further risk assessment of our business and supply chain risks by a third party consultant to ensure our controls in this area are focused most effectively on the highest-risk areas in our businesses and supply chains;
- approval of a new procurement policy to apply to CNI and all our wholly owned subsidiaries, which will address modern slavery risks in our supply chain; and
- the introduction of supplier due diligence and standard clauses to address the risk of modern slavery within our supply chain where appropriate.
This statement has been approved by the Condé Nast International Limited Board of Directors on behalf of CNI and Condé Nast Publications Limited. This statement and CNI’s approach to The Act will be reviewed annually.
The Board of Directors