Modern Slavery & Anti-Human Trafficking Statement

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.

Our Business

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.

Respect for Human Rights

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.

Our Employees

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.

Our Supply Chain / Due Diligence

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.

Our Policies

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:

  • Equal opportunity policy
  • Grievance procedure
  • Modern Slavery statement
  • Whistleblowing policy
Supplier Contracting

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.

Client Contracting

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.

Business Integrity

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.

Employment Agency Policy

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.

Regional Expansion

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.

Our Risk Assessment

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:

  • country risk, as defined by the Global Slavery Index, to identify countries that have a higher modern slavery and human trafficking risk
  • categories of goods and services that we have assessed to have a higher modern slavery risk, as detailed by the United Kingdom’s Gangmasters & Labour Abuse Authority (GLAA), including food and hospitality, FF&E (furniture, fixtures and equipment), security, and technology (hardware products).

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.

Our Commitment (Goals and KPIs)

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:

  • Providing training on modern slavery risks as part of our new employee induction and our annual compliance training, with the aim to achieving 100% compliance
  • Providing all employees access to our statement and training materials
  • Continually reviewing and revising our policies and processes to ensure compliance with the UK Modern Slavery Act and Australian Modern Slavery Act and all local standards in the countries that we operate as they continue to evolve; For policies deemed necessary, we can ask employees to sign and acknowledge they have read and understood the policy
  • Further integrating compliance requirements into a broader base of supplier assessments.
  • Tracking the percentage of new vendors who have acknowledged our Supplier Code of Conduct
  • Drafting and providing functional documentation for the various internal teams to highlight key areas of Modern Slavery compliance
  • Provide supply chain the ability to anonymously report concerns related to modern slavery via our whistleblowing tool
  • Monitor our compliance with applicable whistleblowing regulations and adapt our approach as necessary
  • Completion of annual anti-corruption and anti-bribery training

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.

Subsidiaries Covered
  • FIRST Protocol Group Limited (Parent Company; all others are wholly owned subsidiaries)
  • FIRST Agency Holdings Inc (US)
  • Clive Agency (US) Inc
  • FIRST Global Management Services Inc (US)
  • FIRST Agency Solutions Inc (US)
  • FIRST Protocol Inc (US)
  • FIRST Agency Solutions Holdings Limited (UK)
  • FIRST Agency Solutions Limited (UK)
  • FIRST Agency Solutions PTE Limited (Singapore)
  • FIRST Agency Solutions PTY Limited (Australia)
  • FIRST Events Agency Limited (Ireland)\
  • FIRST Events Agency Ltd (France Branch)
  • FIRST Events Agency Ltd (Belgium Branch)
  • First Events Agency Ltd, Zweigniederlassung Zürich (Switzerland Branch)
  • FIRST Agency Limited (HK)
  • FIRST Agency Holdings Limited (UK)
  • FIRST Protocol Agency Ireland Limited (Ireland)
  • Clive Agency Limited (UK)
  • FIRST Protocol Event Management Limited (UK)
  • FIRST PTE Limited (Singapore)
  • FIRST Agency Limited (Hong Kong)
  • FIRST Global Management Services Limited (UK)


Signed and Approved on June 11, 2024 by:

Name: Edward Stanger
Title: Director
FIRST Group Board

Name: Sam Sherman
Title: SVP, Risk & Compliance