Policy
Below is the Statement under the UK Modern Slavery Act for financial year ending 31 December 2023.
Introduction
S4Capital plc presents its annual statement pursuant to the provisions of section 54 of the Modern Slavery Act 2015 (the Act) for the year ended 31 December 2023. Both S4Capital plc and its group companies will be collectively referred to as ‘S4Capital Monks’ for the purposes of this statement.
S4Capital Monks is committed to upholding the principles of the Act, taking measures to ensure that modern slavery in the form of slavery, servitude, forced or compulsory labour and human trafficking is not taking place in any pert of S4Capital Monks’ business or in those of our clients and suppliers.
At S4Capital Monks, we take seriously our responsibility to conduct business in an ethical way. Monks, a S4Capital Monks subsidiary, has been a member of the United Nations Global Compact since 2012. The United Nations Global Compact is a strategic policy initiative for businesses that are committed to aligning their operations and strategies with 10 universally accepted principles, including in the areas of human rights and employment. We are also committed to upholding the Universal Declaration of Human Rights and the core conventions of the International Labour Organisation.
Organisation's Structure
S4Capital plc (SFOR.L) is the tech-led, new age/new era digital advertising, marketing and technology services company, established by Sir Martin Sorrell in May 2018.
Our strategy is to build a purely digital advertising and marketing services business for global, multinational, regional, and local clients, and millennial-driven influencer brands. This will be achieved by integrating leading businesses in three practices: Content, Data&Digital Media, and Technology Services, along with an emphasis on ‘faster, better, cheaper, more’ execution in an always-on consumer-led environment, with a unitary structure.
The Company now has approximately 7,700 people in 32 countries with approximately 80% of net revenue across the Americas, 15% across Europe, the Middle East and Africa and 5% across Asia-Pacific. The longer-term objective is a geographic split of 60%:20%:20%. Content currently accounts for approximately 60% of net revenue, Data&Digital Media 25% and Technology Services 15%. The long-term objective for the practices is a split of 50%:25%:25%.
S4Capital Monks is led by a highly experienced Board of Directors, details of which can be found here. Our General Counsel, Head of Compliance and Company Secretary is responsible for the day-to-day management our Compliance Programme, including drafting policies and procedures, training and monitoring and provides periodic reports to the Board and the Audit and Risk Committee.
Policies and Code of Conduct
We have several group-wide policies in place that are relevant to modern slavery and continually review, refine and develop our policies.
- Conduct of Conduct - Our code of conduct sets out the clear expectation of us as a company and explains the principles that underpin our ethical standards and is applicable to all S4Capital Monks employees and contract workers in all locations globally, including third parties working on behalf or representing S4Capital Monks. Our code of conduct is available here.
- Supplier Code of Conduct - Our supplier code of conduct, outlines our expectations of the standards we expect suppliers to meet, this includes regarding human rights issues such as child labour.
- Speak up Policy - We encourage anyone, whether working for S4Capital Monks or not, to speak up about misconduct, possible breaches of our Code of Conduct, or other company policies, including our Anti-Bribery and Corruption Policy, our Anti Financial Crime Policy or procedures, and suspected violations of laws and regulations. More information on Speak Up is available here.
Supply Chain and Supplier Due Diligence
The nature of the services S4Capital Monks provides offers limited opportunity for modern slavery and/or human trafficking practices. While this may be the case, S4Capital Monks recognises it remains important to monitor its supply chains to help prevent and identify the risks of modern slavery.
S4Capital Monks seeks to establish and improve its processes to:
- include additional enquiries in its procurement processes for goods, services and locations that are assessed as having a high risk of modern slavery or human trafficking, including an evaluation of any internal policies and procedures such suppliers have in place;
- better (i) identify, assess and monitor potential higher risk areas in our supply chains; and (ii) mitigate the risk of slavery and human trafficking occurring in its supply chains through enhanced contract term controls (to the extent appropriate and obtainable); and
- continue building relationships with known suppliers and ensure that expectations of business behaviour are both clear and consistent.
Implementation
Our commitment to help prevent and identify risks of modern slavery starts with S4Capital Monks' board of directors. The S4Capital Monks Audit and Risk Committee provides oversight on specific issues involving internal and external controls and compliance with legal and regulatory requirements, including compliance with our MSA Statement.
We monitor the effectiveness of our policies and processes and our relationships with suppliers and we regularly report to the S4Capital Monks' board of directors, including material issues.
Effectiveness
We continue to monitor our performance against the following in order to gauge how effective we are in dealing with modern slavery and human trafficking risks in our business or suppliers:
- implementation of our MSA Statement;
- implementation of our Supplier Code of Conduct, which sets out our zero-tolerance approach to slavery and human trafficking and also helps to communicate a number of important related human rights expectations and is in the process of being rolled out to all of our suppliers;
- developing a system for supply chain identification, including, where appropriate, adding modern slavery and human trafficking enquiries and controls to our procurement policies (in accordance with our Supplier Code of Conduct);
- asking specific questions on modern slavery as part of our procurement processes;
- seeking to include protections relating to modern slavery in our terms with third parties for the supply of goods and services;
- implementing a reporting process on key performance indicators on an annual basis, including in relation to training and the roll-out of our Supplier Code of Conduct; and
- enhancing our compliance program to include regular training on modern slavery, as necessary.
Training
We will provide regular training as necessary to educate on the importance of implementing and enforcing effective systems to ensure slavery and human trafficking is not taking place in our supply chains. This will form part of a wider programme of compliance training for all relevant members of management and those in our procurement team, which takes place on a regular basis.
Approvals
This Modern Slavery Statement 2023 was approved by the Board of Directors of S4Capital plc on 30 April 2024.
Sir Martin Sorrell
Executive Chairman
30 April 2024