This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and on behalf of First Protocol Group Limited and its subsidiaries (listed below) for our Fiscal Year ending September 2019.
FIRST is fully supportive of the laws introduced within the United Kingdom through the Modern Slavery Act 2015 to combat slavery, forced or compulsory labour and the trafficking of persons for any purpose. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and 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.
As the leading global events agency, FIRST understands the importance of removing slavery and human trafficking from our global society – we live by our Integrity value inside and outside of our business. This effort is part of our broader human rights agenda within the business that includes corporate action to promote worker protections, broader access to civil rights and community development
Our Business and Structure
First Protocol Group Limited (“FIRST Group”) serves as a holding company for agencies around the world. The entities include those under the FIRST and Clive brand. FIRST Group has subsidiaries in seven countries and those subsidiaries have branch offices that include an additional three countries.
FIRST Group’s holdings provide Strategy, Creative and Design, Venue Sourcing, Event Technology, Planning, Production, and Data & Analytics solutions to a wide range of global brands, through our Events, Experiential and Solutions offerings. Founded in London in 1996, the group has expanded to three hundred plus employees are based out of offices in New York, London, Los Angeles and Singapore. Our clients span many industries including financial services, aerospace, consumer electronics, technology, medical and healthcare, automotive, media and the non-profit sector.
Our Supply Chain
Whilst we resource our core services including operations and account management in-house where we have full control, like many large businesses we have a large supply chain, especially in the on-site fulfilment 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 a number of 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.
FIRST Group has a Global Risk and Compliance Committee, which consists of members of the Legal, Procurement, Operations, People and Culture and Audit. The Committee is led by Sam Sherman, VP Strategic Sourcing & Procurement and its Group Board sponsor Edward Stanger.
Among the responsibilities of this committee is to identify and mitigate risk related to modern slavery. In light of this responsibility, we have reviewed our workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues.
Employee Handbook – FIRST’s handbook makes clear to employees the actions and behaviour expected of them when representing the organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour 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.
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 labour and prohibits slavery, servitude or the use of forced or compulsory labour and human or labour trafficking. FIRST requires heightened contracting standards in regions and industries that have been identified to have a higher risk. We act quickly, removing any supply chain partner where we have reasonable belief that they have fallen out of compliance.
Agency Workers Policy – FIRST uses only specified, reputable employment agencies to source labour and we always verify the practices of any new agency we are using before accepting workers from that agency. FIRST operates a rigorous recruitment and selection process which includes obtaining documented proof of the individual’s right to work in the country they’ll be working in. We pay market competitive wages, and will always pay colleagues at least the minimum wage rate applicable in the geography in which they work.
Training – To ensure a high level of understanding of the risks of modern slavery and human trafficking, each member of our procurement team is required to undergo specific training. This training is aimed to help identify signs of modern slavery in the supply chain and in the work place.
To monitor the effectiveness of our policies, the Global Risk and Compliance Committee is tasked with tracking key performance indicators related to suppliers and agency workers. We will use these indicators to report the effectiveness of our policies on future statements.
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 further training on modern slavery risks as part of our new employee induction and our annual security training.
- Reviewing and revising our policies and processes to include express reference to the Modern Slavery Act and all local standards in the countries that we operate.
- Implementing a Supplier Code of Conduct that includes specific requirements related to modern slavery and human trafficking.
We will continue to work with companies whom we provide services to in order to ensure they are satisfied with our policies and procedures.
- First Protocol Incorporated (United States)
- Barkley Kalpak Associates Incorporated (United States)
- First Protocol Event Management Limited (United Kingdom)
- FIRST Events Agency Limited (Ireland)
- First Pte Ltd (Singapore)
- First Agency Limited (Hong Kong)
- First Agency Servicos de Evetnos LTDA (Brazil)
- Clive Agency Holdings Limited (United Kingdom)
- Clive Agency (Scotland)
- Clive Agency (Ireland)
- Clive Agency Incorporated (United States)
Signed and approved by:
Name: Edward Stanger
FIRST Group Board
Name: Sam Sherman
Title: VP, Procurement
Global Risk & Compliance Committee