Fundamental Media Limited (“Fundamental”, “us”, “we”, “our”) is a leading specialist in media consultancy and advisory services working with the financial industry providing media intelligence, planning and buying. This statement is made in accordance with Section 54 of the Modern Slavery Act 2015 (“the Act”) and sets out the steps we have taken to understand and mitigate the potential human trafficking and slavery risks related to our business. We are committed to conducting business ethically and responsibly and accordingly do not tolerate any form of human trafficking or slavery in any part of our business or supply chain, including, by way of example, through any form of forced work (through mental or physical threat or abuse), any restriction of freedom placed on a worker by an employer, any activity where a worker is treated as a commodity or is bought or sold as property or any form of child labour.
Our group of companies has offices in the UK, US, Hong Kong, and Australia and work with clients from the asset management, securities services, investment and corporate banking, reinsurance and private banking sectors in markets across Europe, Asia and Australia to the Americas. We also work with high profile education institutions promoting undergraduate, postgraduate and professional qualifications. We provide analysis, planning and buying services to our clients; from print and digital media to sponsorship, social media, research, award, event, outdoor and mobile media. In doing so we appoint and buy services from third party media suppliers (publishers and media owners) to supply their services to our clients. We only make such purchases and appointments with the pre-approval of our clients. As a result, our supply chain comprises two types of supplier, (i) those who service Fundamental’s operational requirements across our offices including IT, research, facilities and professional services and (ii) those publishers and media owners who we appoint, with the pre-approval of our clients, to provide their services to Fundamental’s clients. These media suppliers are diverse and spread throughout the geographies in which our clients advertise.
We apply the following practices within our business to help identify and mitigate the risk of modern slavery within our supply chains:
The recruitment of Fundamental’s employees is handled by our local offices but overseen centrally within the UK by our Global HR Manager. We recruit directly and through reputable recruitment agencies who are fully advised of our requirements and expectations that they adhere strictly with the law. References and right to work documentation for applicants are reviewed and followed up in accordance with Fundamental’s References policy. Most employees are recruited by Fundamental to permanent positions; with temporary positions, generally only being used as an interim measure. Fundamental adheres strictly to the standards required of it by employment law including relevant minimum age and wage legislation. Any issues or concerns relating to modern slavery are to be reported to Fundamental’s Global HR Manager who will investigate and act as necessary. Alternatively, employees are encouraged to report any concerns within the business via Fundamental’s whistleblowing policy. Accordingly, the risk of any human trafficking or slavery occurring within the Fundamental business is low.
Fundamental works in accordance with its policies on Business Ethics and Modern Slavery which are communicated to all Fundamental employees and contained within Fundamental’s Employee Handbook. Fundamental is committed to achieving the highest standards of quality, honesty, openness and accountability in all of its activities. Fundamental also believes that it has a moral obligation to take account of the impact of its activities on the local, national and global economy, the environment and the communities in which it operates. As part of this Fundamental does not enter knowingly into business with any organisation found to support or be involved in any form of slavery, nor will we enter into practices which encourage or cause trafficking or slavery in our supply chain.
Our Business Ethics policy also sets out how we are to operate as a business partner and award contracts. Fundamental strives to work with reputable suppliers, who share the same values, and approach (who support non-discrimination, fair treatment at work and who comply with wage and working hours legislation) and who meet our client’s objectives. We have a Supplier Code of Conduct which sets our expectations of our suppliers. This has been updated to reflect the need for suppliers to follow local and national policy in response to the Covid-19 pandemic. In addition, Fundamental works to a standard procurement policy and we require that our employees comply with this at all times. This procurement policy will be kept under review in light of the requirements of the Act. We have mapped the location of material media suppliers to assess the level of risk of modern slavery using Global Slavery Index data and shall continue with this process.
Our standard terms require that our suppliers employ all appropriate measures to eradicate any forced, bonded, trafficked or child labour from their operations and supply chains and cooperate fully with any enquiry we have of their practices in this respect.
This statement relates to our financial year ending 31 December 2019 but includes reference to our approach since then in relation to the Covid-19 pandemic. We are aware that the Covid-19 pandemic is likely to put all supply chains under additional pressures which could lead to new or increased risks of labour exploitation in the coming months and further into the future. We will continue to review our policies and practices in light of these risks.
This statement has been approved by the Chief Executive Officer of Fundamental on behalf of the Board of Directors.
SIGNED: DATE: 25.06.2020