MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2018


Introduction


The MediaKind group provides award-winning media solutions to our customers and this statement describes how MediaKind is tackling the challenge of modern slavery and human trafficking throughout its operations and supply chain and outlines MediaKind´s policies and business practices and plans for future improvements.

MediaKind is committed to human rights, and responsible sourcing and engagement with its suppliers and other stakeholders. Conducting business responsibly is the foundation of MediaKind’s commitment to sustainability and corporate responsibility. We believe that operating our business with integrity, transparency and responsibility is critical to maintain trust and credibility with customers, partners, suppliers, employees, shareholders and other stakeholders. We will continually work to improve and strengthen our business practices, with a focus on transparency, integrity and building trust. This approach enhances risk management and the ability to respond proactively to issues as they arise.

Supply chain


From its headquarters in Texas, USA and its numerous operating companies around the world, the MediaKind group serves customers in more than 150 countries.

Our highly diverse supply chain com­prises global, local and regional suppliers in more than 150 countries which provide a wide range of products and services, such as equipment, installation and consultancy services.

Responsible sourcing is a top priority for us. As the supply chain is large and com­plex, MediaKind adopts a risk-based approach across its group to identify high-risk suppliers and works with its suppliers towards continual improvement.

MediaKind’s position on modern slavery and human trafficking


Taking a strong stance against modern slavery and human trafficking and working to ensure high labour rights standards are core aspects of conducting business responsibly at MediaKind.

Modern slavery and human trafficking is a complex area which impacts throughout the supply chain. Raising awareness about the issue is a key element of the work to improve the standards, both in MediaKind’s own business operations and those of MediaKind’s suppliers and sub-suppliers.

MediaKind has a long-standing policy aga­inst using forced, bonded or compulsory labour, or child labour which is reflected in our Code of Business Ethics and our Code of Conduct. MediaKind’s Code of Business Ethics sets the tone for conducting business globally. It contains rules to ensure that business is conducted with integrity. Everyone working for MediaKind has an individual responsibility to ensure that business practices adhere to the Code of Business Ethics. Employees acknow­ledge the Code of Business Ethics at the time of employment and periodically throughout their term of employment usually through annual certification.

The Code of Conduct, which applies to both employees and suppliers, is based on the UN Global Compact principles. It covers human rights, labour conditions, environmental management and anti-corruption. The Code of Conduct requi­rements are available on MediaKind’s website and forms part of MediaKind’s supplier contracts.

In the Code of Business Ethics and the Code of Conduct, MediaKind expresses a com­mitment to respect all internationally proclai­med human rights including the International Bill of Human Rights and the principles concer­ning fundamental rights set out in the Interna­tional Labour Organization´s Declaration on Fundamental Principles and Rights at Work.

We are also committed to implemen­ting the United Nations Guiding Principles on Business and Human Rights throughout its business operations. Our Code of Conduct clearly states that modern slavery, including forced, bonded or compulsory labour and human trafficking, is strictly prohibi­ted. Employees should be free to leave their employment after reasonable notice as requi­red by applicable law or contract, and employ­ees should not be required to lodge deposits of money or identity papers with the company. We respect the right to equal oppor­tunity, freedom of association and collective bargaining, and we require suppliers to live by the same rules.

Training and awareness


Training and awareness-raising are core to strengthening our employees’ understanding of the importance of respect for human rights, as an integral part of conducting business respon­sibly.

We are always looking for opportunities to raise awa­reness among our employees and suppliers on all aspects of responsible business, including human rights; for instance, in seminars with suppliers. Information about modern slavery and human trafficking has been communi­cated internally within the MediaKind sourcing organization and externally to suppliers to specifically raise awareness on modern slavery and human trafficking.

To further raise awareness within MediaKind, an internal information package including a definition of modern slavery, potential risks and its relevance for MediaKind has been develo­ped. In 2018-2019 the sourcing organization plans to perform modern-slavery focused training in selected market areas and for specific func­tions.

Due diligence


Before selecting a supplier, a mandatory supplier self-assessment is required in the form of a questionnaire covering the Code of Conduct and other relevant areas. We use a risk-based approach to identify relevant suppliers for Code of Con­duct audits. Prioritized risk areas in our supply chain include anti-corruption, labour rights, and com­munication of requirements further down the supply chain.

To further understand the sourcing category groups that have a higher perceived modern slavery risk, MediaKind has reviewed the activities performed in each sourcing category based on workforce skill level and risk of informal employment. Where possible, risk is mapped per sourcing category group to help better understand where the harm of modern slavery and human trafficking would be most severe and where resources should be directed to mitigate risk.

Findings in audits


Supplier Code of Conduct auditors follow up on actions to ensure continual improvement in the supply chain. This includes integrating specific aspects of modern slavery and human trafficking into the scope of supplier audits. MediaKind acknowledges that modern slavery and human trafficking is not easily detected through audits. Therefore, MediaKind plans to complement its audits with targeted supplier workers’ surveys in selected risk areas and countries.

Grievance mechanism


We encourage people to speak up about any concerns regarding the company’s busi­ness practices. We have grievance mechanisms whereby violations of MediaKind’s Code of Business Ethics and other policies and directives can be reported. MediaKind’s whistleblower tool can be used by employees, suppliers and others for reporting alleged violations of laws or the Code of Business Ethics. Violations notified to MediaKind are reported to the Audit Committee for investigation.

We acknowledge that it is difficult to identify modern slavery and human trafficking via whistleblowing tools and so we also focus on awareness-raising activities as an important complementary tool to identify and prevent modern slavery and human trafficking.