This statement on Modern Slavery and Human Trafficking (as defined by the UK Modern Slavery Act 2015 (the “MSA”) and the Australian Modern Slavery Act 2018 (Cth) (the “AMSA”)) sets out the steps we have taken to assess the risk of and ensure that modern slavery and human trafficking are not taking place within our business. This statement on Modern Slavery and Anti- Human Trafficking is made pursuant to section 54 of the MSA and sections 13 and 14 of the AMSA is on behalf of First Protocol Group Limited and its subsidiaries (listed below) for the year ending December 31, 2023.
First Protocol Group Limited (“FIRST”) serves as a holding company for our entities around the world under the FIRST and Clive brands. As of December 2023, FIRST had subsidiaries and branches in 9 countries.
FIRST’ is a leading global brand experience agency providing Content, Creative, Digital Technology, Management & Delivery, and Data & Insights services. Operating as a full-service agency partner or through embedding specialist talent into client teams, FIRST brings together brands and people through creative and connected experiences. FIRST works with clients across industries including financial services, technology, media, consumer electronics, medical and healthcare, automotive, aerospace and the non-profit sector.
While national governments bear the primary responsibility for ensuring human rights, FIRST recognizes the role our business can play in protecting, preserving, and promoting human rights. Our broader human rights agenda within the business includes corporate action to promote worker protections, broader access to civil rights and community development. Our respect for human rights combined with the FIRST core values of integrity, excellence, and teamwork guide how we treat and train our workforce and engage with our clients and suppliers.
FIRST has a Human Rights and Ethics Committee, which consists of members of the Legal, Risk & Compliance, Procurement, People & Culture and Finance departments. The Committee is led by Edward Stanger, Group Board Director.
FIRST aligns our practices to internationally accepted standards, such as the UN Guiding Principles on Business and Human Rights and remains in full support of the laws introduced within the United Kingdom through the Modern Slavery Act 2015. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.
As a leading global brand experience agency operating in multiple countries, FIRST understands the importance of removing slavery and human trafficking from our global society. Examples of this are evidenced in our policies which prohibit forced labor, child labor, and discrimination & harassment. We also maintain an age verification process to confirm all workers are at least 15 years old.
FIRST is committed to creating a workplace that respects each employee’s human rights and ensures their working conditions and interactions with clients and suppliers are consistent with the regulations and laws in the countries in which we operate. We are committed to equality of opportunity in employment to all qualified persons. FIRST is committed to creating a workplace where people can bring their full selves to work and give them a sense of belonging. Our policies and practices illustrate the emphasis we place on fair treatment and the wellness of our people.
Whilst we resource our core services including operations and account management in-house where we have greater control, like many large businesses, we have a large supply chain, especially in the on-site fulfillment of our events. We have identified that many of our direct suppliers are in countries where the risk of slavery and human trafficking is low. We do however work with our suppliers on a regular basis, review their policies and approach to several factors including Modern Slavery and Human Trafficking.
We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors to comply with our values.
We consider the risk of modern slavery, servitude, or human trafficking existing within our business or supply chains to be relatively low. However, we understand that the Modern Slavery risk is not static, and we will continue our approach to mitigating this risk in the year ahead.
We have reviewed our workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues. In addition to our annual statement, our stance is further highlighted in documentation directed toward employees, suppliers, and clients.
The FIRST employee handbook makes clear to employees the actions and behavior expected of them when representing the organization. We strive to maintain the highest standards of employee conduct and ethical behavior when operating locally and abroad and when managing our supply chain. It contains guidance on key identifiers to be aware of and a reporting process in which employees can raise concerns. Specific areas include:
FIRST is committed to ensuring that our suppliers adhere to the highest standards of ethics, and we aim to partner with reputable companies to ensure this. Our standard supplier contract, in addition to requiring suppliers to comply with applicable laws, specifically requires use of voluntary labor and prohibits slavery, servitude or the use of forced or compulsory labor and human or labor trafficking. FIRST requires heightened contracting standards in regions and industries that have a higher risk. Our Supplier Code of Conduct describes the expectations we have of our suppliers to conduct business responsibly including compliance with applicable modern slavery, forced labor, child labor and human trafficking laws. These expectations include prohibition on confiscating worker passports and/or identity documents and on placement, recruiting or processing fees paid by workers to employers. In addition to labor and human rights, the Supplier Code of Conduct addresses the following areas: Ethical Business Practices, Human Rights, Workplace Health and Safety, Environmental Compliance, Data Protection, Workplace Culture and Diversity. The Code of Conduct is now part of our Supplier Onboarding and Contracting.
A violation of the requirements of the Code or supplier contract terms by a Supplier may lead to review or, in circumstances where following engagement with the relevant Supplier such violation is not remedied in a timely and sensitive manner, termination of our relationship.
As part of ongoing revisions and enhancements to FIRST’s client service agreements, specific language has been included to cover the jurisdictional requirements related to modern slavery. These require our clients to comply with the law applicable to them and represent our ongoing commitment to compliance.
FIRST provides various channels through which integrity concerns can be raised without reprisal including a secure platform for our employees, suppliers, and partners to report any concerns regarding possible violations of law, ethics or our policies or risks affecting our people, our organization, society, and the environment.
Concerns can be reported 24 hours a day, seven days a week globally on an anonymous or disclosed basis through an encrypted, password-protected, specialized independent third party. All matters are reviewed and investigated with the highest discretion. We allow no retaliation against a person or business that sends a whistleblower message in good faith. By offering a confidential channel for reporting, we aim to encourage an open and safe environment where our teams and partners feel empowered to speak up including on concerns related to modern slavery, forced labor, child labor and human trafficking that may be affecting our business. In 2023 there were no modern slavery or human trafficking related concerns raised.
FIRST uses only specified, reputable employment agencies to source labor and we always verify the practices of any new agency we are using before accepting workers from that agency. We require that our agency partners follow a rigorous recruitment and selection process which includes obtaining documented proof of the individual’s right to work in the country they will be working in. We require that our agency partners pay market competitive wages and will always pay their workers at least the minimum wage rate applicable in the geography in which they work.
To ensure a high level of understanding of the risks of modern slavery and human trafficking, employees globally are required to undergo specific training. This annual training is aimed at helping identify signs of modern slavery in the supply chain and in the workplace. In addition to this training, we require employees globally complete annual compliance training on anti-bribery and corruption and financial integrity. This training emphasizes the importance of raising red flags, escalation responsibilities and maintaining confidentiality to encourage a culture of escalation, confidentiality, and protection against retaliation. In 2023 we achieved a 100% training completion rate. Our policies are published and on an accessible platform for all employees. Employees are reminded from time to time of the policies and notified of any updates.
Prior to opening a new entity in any region, a business assessment is required which includes evaluating the risks associated with Modern Slavery. In countries where FIRST does not have an established operation, we work with reputable and trusted partners for employer of record services to ensure we remain compliant with local laws and regulations relating to Modern Slavery.
The Human Rights and Ethics Committee is tasked with tracking key performance indicators related to suppliers and agency workers. We have embedded risk-screening criteria into our vendor management program, with the aim of identifying potential risks or modern slavery and human trafficking, particularly in locations or industries that may have a high turnover of vulnerable workers, which lends itself to many forms of modern slavery.
Our risk-screening criteria includes the following indicators to help inform our risk assessment with respect to potential areas of vulnerability in our supply chains:
In addition to the above, our due diligence includes standard sourcing and contracting procedure to address modern slavery and human trafficking including contractual provisions in relevant vendor contracts. During sourcing, all vendors are required to sign off to acknowledge they have read and understood our Supplier Code of Conduct. Our vetting process also includes specific due diligence questions related to modern slavery and human trafficking. Our standard supplier contract, in addition to requiring suppliers to comply with applicable laws, specifically requires use of voluntary labor and prohibits slavery, servitude or the use of forced or compulsory labor and human or labor trafficking.
In the next year we plan to expand our due diligence on vendors to screen them for potentially adverse information, including basic human rights related information, during the onboarding process.
We will continue to assess the risks associated with our supply chain and expand the scope of our focus as necessary.
Over the next 12 months, we will continue our current approach to managing the risk of slavery and human trafficking within our business. Our ambitions include:
We will continue to engage with our people, our clients, and our suppliers to raise awareness and to take steps necessary to ensure modern slavery and human trafficking are not taking place within our business or supply chain.
Signed and Approved on June 11, 2024 by:
Name: Edward Stanger
Title: Director
FIRST Group Board
Name: Sam Sherman
Title: SVP, Risk & Compliance