Introduction
This statement sets out the steps that Global has taken across the Global group to address the risks of modern slavery in any part of its business, operations or supply chains.
Global’s business structure
The Global group is one of the world’s leading media & entertainment groups incorporating radio, outdoor advertising and our digital advertising platform, DAX (“Global”). Global has over 2000 employees worldwide and operates in the UK, Ireland, Netherlands, Spain, North America and Canada.
Our ultimate parent company is Global Media & Entertainment Limited (company number: 6251684) which has its head office in England. This statement is made on behalf of Global Media & Entertainment Limited and its respective subsidiaries including Global Outdoor Media Limited, Global Media Group Services Limited, Global Radio London Limited and Primesight Limited.
Our supply chain
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We do this by requiring that our suppliers comply with all applicable laws, which includes the Modern Slavery Act 2015.
Our key suppliers for the financial year ending March 2021 supplied us with the following goods and services:
• outdoor advertising inventory – rentals and asset build
• radio transmission and distribution services
• contractor services
• outdoor advertising collateral – design, production and print
• property
• professional & consultancy services
• IT/ technology services
Our Supplier Code of Conduct (which can be found here) reflects our commitment to acting ethically and with integrity in all our business relationships to ensure slavery and human trafficking is not taking place anywhere in our supply chains. Global is firm in its resolve to do business only with those companies who share in its commitment to conduct business responsibly, with integrity and transparency.
Global chooses suppliers to work with on the basis that they meet the same high business standards set out by it. Global places an obligation on the suppliers it engages with to ensure that compliance to the Supplier Code of Conduct is passed down and communicated through the supplier’s own supply chain where applicable. Our Supplier Code of Conduct is expressly referenced and incorporated in our standard purchase terms and conditions and supplier contracts.
Supplier Vetting
As part of our initiative to identify and mitigate risk with the suppliers that we work with, Global adopts a supplier vetting process to support the business in delivering best practice and ongoing due diligence. The supplier vetting process applies to both existing supplier base as well as when approaching potential new suppliers. The supplier vetting process allows for the governance around Global’s supplier base to be strengthened by ensuring a minimum vetting and governance criteria is met. This is of importance particularly around suppliers that provide goods and/or services that are business-critical to Global.
The supplier vetting process is managed by the procurement team and reviews suppliers through desktop audits. The minimum standards set out by Global are reviewed annually to ensure that the latest regulations and legislation are incorporated.
The supplier vetting process reviews a supplier’s capabilities and credentials including but not limited to the following:
• general company background check;
• financials and statement of accounts;
• operational capability and geographical scope;
• insurances held;
• HSSE compliance & respective processes and policies;
• information security and data protection compliance;
• anti-slavery and trafficking compliance;
• anti-corruption, anti-bribery and anti- tax evasion compliance; and
• environmental and sustainability policies and procedures.
The supplier vetting process verifies a supplier’s compliance to Global’s standards annually and if a supplier does not meet the standards, a further review is carried out to consider the supplier’s future engagement with Global. This review may consist of both a desktop and/or physical site audit of the supplier’s operation and processes.
Supplier adherence to our values
We have zero tolerance to slavery and human trafficking. As part of Global’s supplier vetting process, any existing or new supplier that wishes to work with Global must adhere to Global’s Supplier Code of Conduct alongside any other relevant Global policy that is applicable to suppliers.
We have controls in place across the following departments of our organisation to carefully select and monitor our suppliers: Procurement, Finance, Technology, People & Culture, Sales, Legal and Compliance.
Further steps
Following a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chains, we intend to take the following further steps:
• Continue to review internal processes and procedures to ensure effectiveness in combating slavery and human trafficking.
• Review our relationships with supply partners to ensure companies appointed by Global meet and exceed the same minimum requirements in combating slavery and human trafficking; and
• Implement minimum targets internally and with our supply partners to ensure transparency of how we are meeting Global’s minimum requirements.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Global’s slavery and human trafficking statement for the financial year ending March 2021. It was approved by the board on 22nd September 2021.
Darren Singer, CFO
Global Media & Entertainment Limited
Date: 22 September 2021