Modern Slavery and Human Trafficking Statement

Leo Burnett

ANTI-SLAVERY AND HUMAN TRAFICKING POLICY

Introduction

The following UK policy on anti-slavery and human trafficking has been drafted in order to comply with the Modern Slavery Act 2015 (the “Act”). It extends to all of Leo Burnett’s business dealings and transactions in all countries around the world in which Leo Burnett carries on business.

1. POLICY STATEMENT
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. The Group has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its business or in any of its supply chains.

Leo Burnett is committed to ensuring there is transparency in its business and approach to tackling modern slavery throughout its supply chains, consistent with its disclosure obligations under the Act. Leo Burnett expects the same high standards from all of its contractors, freelancers, suppliers and other business partners. As part of its contracting processes, Leo Burnett includes specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and it expects that its suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for Leo Burnett or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, freelancers, external consultants, third-party representatives and business partners (“Leo Burnett Staff”).

This policy does not form part of any employee’s contract of employment and may be amended at any time.

2. RESPONSIBILITY FOR THE POLICY
The Group’s UK Compliance Officer has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery and human trafficking.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

3. SUPPLIERS
Suppliers of Leo Burnett are required to comply with the supplier code of conduct (the “Code”)provided to them. The Code sets out minimum behaviours, standards and practices Leo Burnett expects to see from its suppliers to ensure compliance with the Act. Leo Burnett expects all who seek to have a business relationship with Leo Burnett or any member of the Publicis Groupe(the “Group”) to familiarise themselves with the Code and act in a way that is consistent with it.

4. LEO BURNETT STAFF
All Leo Burnett Staff must ensure that they read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of Leo Burnett’s business or supply chains is the responsibility of all Leo Burnett Staff. Leo Burnett Staff are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your manager or Leo Burnett’s compliance officer as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of slavery and/or human trafficking in any parts of Leo Burnett’s business or supply chains of any supplier at the earliestpossible stage. In order to help identify modern slavery, there are a number of indicators that you should be aware of. Not all the indicators will apply in every case, and some may not be immediately apparent. The indicators include, but are not limited to:

(a)  Restricted freedom

Victims of slavery and/or human trafficking may not be in control of their passports or other travel or identity documents. They may have false identity documents or are unable to move freely.

(b)  Behaviour

Victims of slavery and/or human trafficking may be unfamiliar with the local language or may act as if they are instructed by someone else. They may show fear or anxiety and be distrustful of authorities.

(c)  Working conditions
Victims of slavery and/or human trafficking may have no contract or be unable to negotiate working conditions. They may be forced to work under certain conditions or work excessively long hours over long periods. They may lack basic training or professional licences.

(d)  Accommodation

Victims of slavery and/or human trafficking may not know their home or work address. They may live in poor or substandard accommodation, or have no choice where they live or who they live with.

(e)  Finances

Victims of slavery and/or human trafficking may receive little or no payment, or have no access to their earnings. They may be disciplined through punishment or fines. They may be forced to open bank accounts or forced to sign documents to receive social security benefits, credit agreements or loan agreements.

 (f)  Appearance

Victims of slavery and/or human trafficking may suffer injuries that appear to be the result of an assault, or the result of the application of control measures.

For a full list of potential indicators please visit http://www.gla.gov.uk/who-we-are/modern-slavery/who-we-are-modern-slavery-spot-the-signs/

If you believe or you suspect modern slavery, human trafficking and/or a breach of this policy has occurred or may occur you must notify your line manager or Leo Burnett’s compliance officer or report it in accordance with our Whistleblowing Policy (which can be found here \\Gbkenpfslbw0004\leobbrand\Group-File-Exchange\The Notepad) as soon as possible.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of Leo Burnett’s supply chains constitutes any of the various forms of modern slavery, raise it with your line manager or Leo Burnett’s compliance officer.

Leo Burnett encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. Leo Burnett is committed to ensuring that no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of Leo Burnett’sbusiness or in any of its supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform a member of the HR team immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the Grievance Procedure, which can be found here \\Gbkenpfslbw0004\leobbrand\Group- File-Exchange\The Notepad

5. COMMUNICATION AND AWARENESS OF THIS POLICY
Training on this policy, and on the risks Leo Burnett faces from modern slavery in its supply chains will be provided as necessary.

Leo Burnett’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

6. BREACHES OF THIS POLICY
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

Subject to the relevant contractual terms, Leo Burnett may terminate its relationship with other individuals and organisations working on its behalf if they breach this policy.