Walker Guidelines

UK Tax Strategy

Introduction

This UK Tax Strategy sets out the approach of the Williams Lea Tag Group (the WLT Group) to risk management and governance arrangements in relation to UK taxation. It applies to all UK entities in the WLT Group within the charge to UK Corporation Tax and covers the attitude towards tax compliance, tax governance, tax planning and tax risk management as well as the approach to dealing with the UK tax authorities (HMRC).

The publication of this UK Tax Strategy complies with the requirements of the Finance Act 2016 Schedule 19 paragraphs 19(2) and 19(4) for the financial year ending 31 December 2022 and remains in force from the date of publication until it is superseded.

Approach to Tax Risk Management and Tax Governance

As a multinational organisation, the WLT Group is exposed to a variety of tax risks. The WLT Group looks to manage tax risks in a similar way to other risks in the WLT Group.

The Finance function is responsible for monitoring tax risks within the business and internal controls are put in place to identify, quantify and manage those risks. Day to day management of the WLT Group’s tax affairs is delegated to the Group Head of Tax, a senior member of the Finance function who reports directly into the Group Chief Financial Officer (“GCFO”). The GCFO is the Board member with executive responsibility for tax matters. Ultimate responsibility for tax risk management and tax governance rests with the WLT Group Board.

The WLT Group is committed to full compliance with all statutory tax requirements and full disclosure to relevant tax authorities. The WLT Group’s tax affairs are managed in a way which takes into account the group’s wider corporate reputation in line with the group’s overall high standards of governance.

Attitude Towards Tax Planning

The WLT Group understands its responsibilities in complying with all relevant tax legislation and regulations in every country in which it operates. The WLT Group reserves the right to structure its affairs in a tax efficient manner and to utilise tax reliefs and incentives in accordance with intended government policy objectives. The WLT Group does not enter into wholly artificial structures or transactions which serve no commercial purpose other than to avoid tax.

All WLT Group employees are subject to the Code of Conduct provided to them when joining the business and this is available on the employee intranet.

External advice may be sought in relation to any area of taxation, including tax compliance processes, tax structuring and tax planning.

Level of Acceptable Tax Risk

There are no formal levels of acceptable tax risk. Tax risks are managed on the same basis as other risks within the business. The WLT Group is fully committed to complying with all tax laws and regulations in each of the countries in which it operates.

Approach towards Dealings with HMRC

The WLT Group seeks to establish and maintain an open and constructive relationship with HMRC. The WLT Group is committed to compliance with all statutory obligations and undertakes to provide full disclosure of all relevant matters. Where appropriate, the WLT Group will engage with HMRC at an early stage to address any areas of uncertainty and seek to resolve disputed matters in a timely manner.

The Walker Guidelines

The private equity industry faced significant reputational challenges in the UK in 2007 and 2008, and as a result, the British Private Equity and Venture Capital Association commissioned Sir David Walker to conduct a review into disclosure and transparency within the industry. This review led to the development of the Walker Guidelines, which apply to the largest private equity-backed companies in the UK and operate on a ‘comply or explain’ basis. The Walker Guidelines are the cornerstone of activities to demonstrate the UK private equity industry’s commitment to transparency of its activities. Williams Lea Tag group intends to comply with these guidelines, with the exception of the non-financial KPIs as explained later in this report.

Ownership

The AI Wertheimer Holdings Group is owned by funds containing institutional owners.  It is controlled by funds advised by Advent International Corporation, a private equity investment company.

About Advent International

Founded in 1984, Advent International Corporation (“Advent”) is one of the largest and most experienced global private equity firms. With offices on four continents, Advent has established a globally integrated team of more than 470 investment professionals, focused on buyouts and growth equity investments in five core sectors. Since beginning its private equity strategy in 1989, Advent has invested $61 billion in over 390 private equity investments across 42 countries, and as of 31 December 2021, manages $88 billion in assets. For more than 30 years Advent International has sought to invest in well-positioned companies and partner with management teams to create value through sustained revenue and earnings growth.

The board that directs and controls the group operates at the level of a subsidiary company, Wertheimer UK Limited.

Directors of Wertheimer UK Limited
The directors who hold office were as follows:

Appointed

Messrs Brocklebank and Benson are representatives of Advent International and the investment funds managed by Advent.

Short biographies for the current Board members (including Advent directors) are shown below:

Ralph Kugler (Chairman Williams Lea Tag)
Ralph has over 26 years of experience in senior executive positions within international and FTSE-100 businesses. He previously served on the Board of Unilever PLC, spending 29 years in a variety of roles and has also held Non-Executive positions at Intercontinental Hotels Group PLC and Mars, and is a former Senior Advisor to 3i Group.

Gary McGaghey (Chief Financial Officer Williams Lea Tag)
Gary has a wealth of experience from various industries as a CFO with a track record of building world class finance teams, delivering organic and M&A driven growth and value in private equity. Prior to joining WLT as the Interim Group Controller, Gary was Group CFO at Nelson & Co Ltd. Prior to that he held various executive financial roles within Unilever.

James Brocklebank (Managing Partner at Advent International Ltd – London)
Experience: James Brocklebank joined Advent in 1997. Based in London, he  co-chairs Advent’s global Executive Committee and is co-head of the firm’s  European business. He is a member of the Europe and North America Investment Committees.  His sector focus is Business and Financial Services. James sits on the Advisory Council of Level20, is chairman of the Private Equity Taskforce of the Sustainable Markets Initiative (SMI) and is a member of the CFR’s Global Board of Advisors. Prior to Advent, James worked on international mergers and acquisitions in the London office of investment bank Baring Brothers and its affiliate Dillon, Read & Co. in New York. James has an MA from Cambridge University.
Investments:  James has worked on 17 Advent investments, including Concardis GmbH, Equiniti, GFKL, Nets, Nexi, V. Group, Williams Lea Tag and Worldpay
Directorships: Current: V.Group Limited, Williams Lea Tag
Previous: Equiniti, MACH, Tertio Telecoms, Worldpay, Nexi, Nets Holding

Chris Benson (Director at Advent International Ltd – London)
Experience: Chris Benson joined Advent in 2012. Previously, he worked for Actis, an emerging market private equity fund, making investments across Africa, Asia and Latin America. Prior to Actis, he was a consultant with OC&C Strategy Consultants in London.

Chris has an MA in Philosophy, Politics and Economics from Oxford University and an MBA from Harvard Business School, where he was a Fulbright Scholar.
Investments: Chris has worked on Advent’s investments in Nexi, Evri, Towergate, V.Group, Williams Lea Tag and Worldpay
Directorships: Current: Williams Lea Tag

Financial position

Borrowings

The Group’s borrowings at 31 December 2021 were put in place at the time of the acquisition by Advent International on 30 November 2017. On 6 May 2022 the Group completed a refinancing of its existing borrowings whereby a new funding structure was put in place comprising a financing facility of €310m and a further acquisition facility of €50m both repayable in 2027 and a revolving credit facility of €40m maturing in 2025.  On 10 May 2022, the existing senior bank and payment in kind loans were repaid in full.

Senior facilities

The Group’s financing facilities with a syndicate of lenders comprised senior loans of €120m and a revolving credit facility of €30m, which were secured by a charge over all of the Group’s subsidiaries. Interest was charged at a rate of EURIBOR (subject to a 1% floor when EURIBOR is less than zero) plus a margin of 5% and 3% on the senior loans and revolving credit facility, respectively. Interest on the senior loans was payable on a quarterly basis or semi-annually, at the discretion of the Group. Drawdowns of the revolving facility during the year ended 31 December 2021 which remained outstanding at year end totalled €28.5m (2020: €25.4m).

The senior facilities agreement included one financial covenant, a leverage ratio, which was tested on a quarterly basis. The covenant required that the Group’s net debt as at 31 December 2021 did not exceed 3.00 times (2020: 3.00 times) its adjusted consolidated EBITDA. At all testing periods during the year, the covenant tests were met. At year ended the Group’s leverage ratio was 1.88.

Hedging instruments

The Group has entered into forward foreign currency contracts to mitigate the exchange rate risk for certain foreign currency payables incorporating an interest rate swap to hedge the Group’s exposure to interest rate movements on the Senior bank loans.

Payments in kind loan

The Group’s borrowings as at 31 December 2021 included a PIK loan of €134.5m (2020: €124.1m) provided by Deutsche Post DHL . No repayments of the PIK loan were made during the year (2020: nil). This loan was secured by a charge over all of the Group’s subsidiaries and interest charged at a rate of EURIBOR (subject to a 0% floor when EURIBOR is less than zero) plus a scaled margin starting at 6.25% in year one and rising to 9.5% in year six. Interest was capitalised and to be settled on the date of final repayment. The PIK loan, which was repayable on 31 May 2023, was repaid on 10 May 2022 following the new financing arrangements entered into on 6 May 2022.

Financial risk management

The Board of Directors has overall responsibility for the establishment and oversight of the Group’s risk management framework. The Group’s activities expose it to a variety of financial risks including inflation risk, credit risk, contract risk, market risk and liquidity risk.

Inflation risk

Inflation arises when goods and services sold by the Group are purchased from external suppliers. These costs are subject to regular review and competitive procurement processes. The Group is partially exposed to commodity price risk as a result of key raw materials historically showing volatility in price. These relate principally to the strategic sourcing service line and are also subject to regular review and competitive procurement processes. Where possible the Group passes the effects of such volatility on to its customers. Where not possible, this is communicated and the risk assessed by senior management.

Credit risk

Credit risk is the risk of financial loss to the Group if a customer fails to meet its contractual obligations. Credit risk management follows normal best practice and includes varying levels of credit assessment according to customer size and active credit performance management through key performance indicators such as days’ sales outstanding. As the customer base is predominantly blue chip multinational clients, the risk of a major client defaulting is considered low.

Contract risk

Contract risk is the risk of financial loss to the Group arising from contract breach. Contract risk is managed by a formal contract approval processes, active operational management and, in some cases, certain risks are insured.

Market risk

Market risk is the risk that changes in foreign exchange rates and interest rates will affect the Group’s income or costs.

• Foreign currency risk is attributable to investments, financing measures and operating activities. Cross-currency swaps are used to limit foreign currency risk where appropriate. These transactions relate to the exchange rate hedging of material payments covering general
  business activities that are not made in the functional currency of the respective Group companies. The principle of matching currencies applies to the Group’s financing activities.
• Hedging transactions performed in 2021 as part of foreign currency risk management related primarily to sterling, the US dollar and the Euro.
• Interest rate risk results from changes in market interest rates, primarily for medium- and long-term debt. Interest rate swaps, cross-currency swaps and other types of interest rate contracts are entered into to hedge against this risk primarily under fair value or cash flow hedges and depending on market conditions.

Liquidity risk

Liquidity risk is the risk that the Group will encounter difficulty in meeting obligations associated with financial liabilities. The Group aims to mitigate liquidity risk by managing cash generation by its operations and maintains funds on demand to meet all operational expense including the servicing of financial obligations.

Principal activities

The Williams Lea Tag Group is a leading independent marketing and communications partner to businesses worldwide, enabling customers to activate their marketing strategies and optimise their communications. The Group comprises two distinct businesses: Tag, leading independent marketing activation partner, and Williams Lea, leading global provider in skilled, business-critical support services to law firms, investment banks, and professional service firms.

As a leading independent marketing execution partner, the Group is trusted by global brands worldwide to turn creative ideas into reality, working with clients to provide an end-to-end marketing execution service, powered by the latest innovations, advanced data analytics and deep digital expertise. As the first creative production company to provide full transparency of production spend, they are leaders in outsourced procurement with a range of flexible and cost-efficient models to deliver solutions across any channel anywhere in the world.

As a leading independent communications optimisation partner to legal and financial services firms worldwide, the Group enables customers to focus on their core activities and optimise people and resources to drive success. Using global expertise and local knowledge, the Group helps customers navigate complexity and constant change by building solutions focused on process optimisation, advanced technology and expert activation via the best people in the industry.

Principal risks and uncertainties

The Group assesses risk at board level and through other operational boards which meet on a regular basis. The principal risks and uncertainties facing the Group are set out below:

General business environment
The business of the Group substantially depends on the financial health of our customers which in turn depends on the global macro-economic environment.

Competition
The Group operates in a competitive environment and all contracts and processes are subject to regular analysis with the aim of retaining existing customers, growing the customer base and optimising the economic performance under customer contracts.

Employees
The hard work, expertise and commitment of its employees are essential to the commercial success of the Group and a high priority is placed on the effectiveness of employment practices and human resource development initiatives. Actions and programmes in relation to employee engagement and involvement are described in the Directors’ report.

Information technology and cyber risks
Information technology is an integral part of the Group’s service capability and its business performance depends heavily on the functioning and performance of its applications and infrastructure. Active risk management processes are in place to maximise the efficiency of the Group’s technology. The directors continuously monitor data security compliance and risk.

Key performance indicators 

Given the significant changes in the Group structure during the year and the implementation of new reporting systems, a full data set is not yet available to externally report performance against all of our KPIs.

A number of these measures are already being reported on internally and as the business structure matures and our internal systems evolve, a greater range of Group financial and non-financial KPIs will be presented.

In the future, the Group expects to report non-financial KPIs such as FTE numbers, FTE utilisation rate, FTE attrition, diversity and inclusion index and number of customers.

Business model

The Williams Lea Tag Group is a global provider of marketing production and skilled business-critical support services worldwide. The Group comprises two strategic business units, Williams Lea and Tag.

The Group’s purpose is to create value for its clients by working smarter, leveraging technology, enhancing efficiencies, improving their customers’ experience and strengthening their brand reputation. The Group’s clients and their customers are at the heart of everything the business does. Long-term partnerships, strong relationships, exceptional employees and leading technology have been the driving force behind the Group’s success.

Williams Lea

Williams Lea is a global provider of skilled business-critical support services to financial, legal and professional services firms, connecting people, processes and technology to streamline key business and administrative functions and helping companies adapt to a more virtual and digital workplace.

Built on a strong heritage, great client relationships and a talented team  Williams Lea is the trusted global outsourcing provider to clients in highly regulated environments.

Tag

Tag is a leading independent end-to-end, technology-enabled, global content production powerhouse, serving the world’s leading brands. Tag offers a complementary skillset to in-house teams and advertising agencies to bring to life, extend and deploy creative ideas. Tag also has a unique ability to scale master assets into bespoke omnichannel content through offshore hubs and benefits from local teams of creative talent and account managers across the world.

Business situation and strategy

The key future strategies to deliver growth in the Group’s marketing production and skilled business critical support services are as follows:

• The creation of two strategic business units – Williams Lea (Business Support Services) and Tag (Marketing Production and Sourcing Services) with separate leadership and business plans.
• Investment in broader digital capabilities to drive efficiencies improve the client offering.
• Customer excellence programme to drive commercial effectiveness including investment in next generation technology platforms to enhance client experience and value.
• Building the mergers and acquisition pipeline to bolster Group capabilities and to bring in additional service lines as well as continued geographical expansion.

Outlook

During 2021 the management and directors of the business have acted to mitigate the impact of COVID-19, and the Group’s 2022 plans consider the implications of decisions taken. For Tag, client MDs encouraged clients to move spend towards digital, video & postproduction services, and Tag has benefited from an acceleration of the shift to digital offerings (e.g. Pharma and Consumer Retail). Across Williams Lea, the initial impacts primarily were to office services typically provided onsite as client offices remain closed to staff before starting to open up in Q4 2021, resulting in a strong recovery. Business Services  and Presentation Services remained strong throughout 2020 and the business showed growth in 2021 through providing  virtual solutions for clients, and these services remained critical in delivering client needs.  The business growth experienced in 2021 is anticipated to continue as clients continue to shift business critical services to specialist outsourced providers. More widely, the nature of the multi-country business offered further protection of volumes as markets were impacted by COVID-19 in differing degrees and at differing times across the Globe.

Williams Lea

Market dynamics are providing Williams Lea with significant growth opportunities.  COVID-19 accelerated the tendency to outsource across many industries. The cost inflationary environment being experienced globally is driving businesses to focus on optimisation and cost saving through outsourcing. Seismic shifts in employment market dynamics driven by COVID-19, whereby working from home has become a more acceptable norm, has made remote service delivery options accepted by clients, which has accelerated the shift to outsourcing. These markets shifts, particularly in the legal and investment banking industries where Williams Lea has a strong presence, provides significant growth opportunities. Furthermore, digitalisation and automation are opening up new opportunities to Williams Lea, both in terms of upgrading existing support services, as well as introducing new solutions. Significant investments in technologies have provided Williams Lea a strong foothold in the fast growing segment of digital support services to professional firms.

Tag

Market dynamics are providing Tag with significant growth opportunities. The customer journey is becoming more and more omni-channel, where Tag is well positioned to take advantage of the increase in digital asset creation. Advertising has become more and more digital, with an acceleration in e-commerce, with more people shopping on-line and interacting through social media, a shift accelerated by COVID-19.  Management is confident Tag’s global footprint  enables economies of scale, and that its proprietary digital infrastructure enables the provision of high quality services which excel in delivering on clients’ value propositions.

Employees

The Group believes that the wellbeing of its employees and their active participation in two-way communication forums is fundamental to the success of the business. Regular meetings, conference calls and webcasts are held where Company strategy and operational matters are discussed. Training is provided according to structured training and development plans for employees at all levels.

Employee engagement surveys are conducted annually and the most recent one had a higher participation rate than in recent years. The results of the survey are built into communication and consultation plans for each employee or, where more relevant, groups of employees.

Full consideration is given to all applications for employment and to treat all staff fairly, regardless of gender, religion, race, age or disability. Where existing employees become disabled, it is the Company’s policy, where practicable, to provide continuing employment under normal terms and conditions and to provide training and career development and promotion opportunities to disabled employees.

Senior employees participate directly in the success of the business through the Group’s bonus schemes. The organisation publishes information on the Career and Development Plan (CDP) portal about its climate change impacts and CO2 emissions.

Our Learning

Learning and development (L&D) is a constant focus, where we react to industry developments and client demands by continually learning new disciplines. Our investment in our people is vital to professional and personal development and assures both our people and clients we are committed to their growth.

We promise to provide all employees with ample opportunity to build on existing skills but encourage growth into new disciplines across industry practices. We want to cultivate a place of work where employees feel they are performing at their best, growing in confidence, exploring internal prospects and ultimately, reaching their full potential.

In 2021 we:

• Invested €140k in people’s L&D globally
• Invested €250k in Cornerstone L&D Platform globally
• Enrolled 40 employees in INSEAD/MSU business school programmes
• Facilitated a Tag Future Programme for 40 employees
• Facilitated a Tag Global Mentorship Programme for 40 employees
• Invested €50k in 40 Mini MBA (global)
• Invested €1.05m in our Poland Street Offices to give our employees and clients a creative and collaborative space to work

Gender diversity information

The Group is committed to providing equal opportunities in employment and eliminating unlawful and unfair discrimination in employment and against clients.

The Group values the differences that a diverse workforce brings to the organisation and will not discriminate because of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (which includes colour, nationality and ethnic or national origins), religion or belief, sex or sexual orientation (each of these being a “protected characteristic” in discrimination law). It will not discriminate because of any other irrelevant factor and will build a culture that values openness, fairness and transparency.

The gender split of the Group’s work force at the end of December 2021 is set out below:

In accordance with the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017, the Company published our Gender Pay Gap Analysis which can be viewed on the Company Website.

Williams Lea

Williams Lea is committed to providing equal opportunities in employment and eliminating unlawful and unfair discrimination in employment.

Williams Lea values the differences that a diverse workforce brings to the organisation and will not discriminate because of age, disability, marriage and civil partnerships, pregnancy and maternity, race (includes colour nationality, and ethnic or national origins), religion or belief, sex or sexual orientation. It will not discriminate because of any other irrelevant factor and will build a culture that values openness, fairness and transparency.

View Williams Lea’s 2022 Gender Pay Gap Report.

Environmental matters

The Group recognises that environmental issues are a fundamental challenge for the global community. The business is committed to managing the environmental impacts that arise through the lifecycle of its products and services.

The Group has in place an Environmental Management System that demonstrates our commitment to environmental protection, pollution prevention, waste reduction and the preservation of our natural resources. We recognise our responsibility to manage the environmental impacts that arise through operations and the need to support our clients in achieving their environmental objectives. We believe we can affect positive environmental change within the market in which we operate and within the supply chain, that supports our products and services.

The Board supports our Williams Lea and Tag integrated Safety, Health, Environment and Quality (SHEQ) policy as it seeks to add value by safeguarding our reputation, minimising loss, improving our sustainability performance and providing continued service delivery.

Our Williams Lea and Tag SHEQ Policy sets the high level structure within which the Group can meet its legal, regulatory and contractual obligations. We identify our environmental aspects and impacts within our operations and manage these in accordance with good industry practice.

The Group’s SHEQ objectives include:

• We are committed to ensure that no harm occurs to our people or those affected by our operations.
• We strive to reduce waste and minimize pollution from our business operations.
• We aim to ensure, our products and services are sustainable by having low impact to the environment including reducing our carbon emissions, efficient use of resources and responsible supply chain management.
• We strive to deliver world leading products and services that satisfy customer’s needs, through the implementation of quality processes.
• All our activities, products and services will comply with applicable legislation, contractual requirements, and company policies.
• We are committed to ensuring our people are competent by providing required training, information, and supervision to enable them to provide the highest quality of products and services in a safe manner.
• We strive to continuously improve our SHEQ management systems to enhance our performance through measurable SHEQ targets.
• We align our health & safety management system with ISO 45001, our environmental management system with ISO 14001, our quality management system with ISO 9001 and maintain accredited certifications where required.

Key environmental aspects and impacts for the organisation include CO2 emissions, waste management and resource use.  The organisation publishes information on the CDP portal about its climate change impacts and CO2 emissions.  Actions taken in 2021 to reduce emissions include consolidation of property portfolio and reduction in use of associated utilities. Reduction in business travel and improved use of technology to facilitate collaboration.

The business also takes part in the EcoVadis scheme to disclose its performance in relation to Environmental Social Governance (ESG) to relevant interested parties.

During the 2021 submission the Group achieved a gold rating from EcoVadis with 69%. The details of our business energy use and CO2 emissions for the UK are listed below:

*Scope 1&2 energy use
**Scope1,2 & partial scope 3 emissions

Methodology

Methods for calculating the energy use and CO2 emissions are following the government guidance (Environmental Reporting Guidelines: Including streamlined energy and carbon reporting guidance). Conversion factors used are those published from the Department for Business, Energy & Industrial Strategy for the relevant year. The period of reporting covers the company financial year running from January 1st to December 31st.

Scope and boundary

The scope and boundary of the energy data which has been reported is limited to the UK operations only at this point. In many cases the organisation operates on client sites and energy use for the client facility is not included in our reporting.

Scope 1 emissions are predominantly from natural gas used for heating and domestic water along with some fuel for fleet vehicles / business mileage.

Scope 2 emissions are predominantly from procured energy such as electricity supply to our premises.

Scope 3 emissions are partial and mainly in relation to procured business travel such as rail travel, air travel and hotel stays.

Data for gas and electricity use is taken from actual invoice data. The data for scope 1 business mileage is a combination of actual mileage readings and estimated emissions for vehicle types. Data for scope 3 procured business travel is estimated by emissions for vehicle types and standard industry practises.

Social community and human rights issues

The Group is developing its Corporate Social Responsibility (CSR) strategy to widen its reach and measure its impact across the many communities we engage with. The Group performed the Corporate Social Responsibility using the EcoVadis methodology and platform, where a Gold (2020: Gold)  Rating was achieved. Our impact was assessed across four themes: environment, fair labour practices, ethics/fair business practices, and supply chain, and against 21 key CSR indicators.

Pursuant to Section 54(1) of the Modern Slavery Act 2015 the Group has taken and is continuing to take adequate practices to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Our People

In 2021, the formation of dedicated global DE&I (Diversity, equity and inclusion) teams drove initiatives that would make a difference to our people. We aim to break down barriers, encourage conversation and ignite ideas.

We want all employees to have a voice, to openly express who they are and to feel safe, respected and valued. DE&I at the Group is an all-inclusive request for equality that encompasses gender, gender identity, age, race, religion, ethnicity, disability and more.

Collecting global baseline data was key to identifying opportunities where we can improve diversity across genders, and race/ethnicities; this helped us establish measurable DE&I objectives and programmes for the forthcoming years.

We are proud to have:

• A diverse team spanning the globe
• Completed training to aim to eliminate bias
• 50% of women in leadership positions (directors and above) bolstered by Internal Women in Leadership
• programmes (EMEA)
• 16% mean pay gap of basic salary of FTE based on gender and further plans to reduce this (EMEA)
• Collected baseline data globally to identify opportunities to improve diversity
• Over 12 DE&I initiatives to get employees involved across 2021 around Family, Gender Equality, LGBT+, Mental Health and more (Global)
• New talent acquisition tactics to establish more diverse talent pools and inclusive recruiting methods.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. The Group has a zero-tolerance approach to any form of modern slavery. We are strongly committed to playing our part in eradicating modern slavery by ensuring we act ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our Policies

Our internal policies ensure that we are conducting business in an ethical and transparent manner, such as:

• Recruitment policy– This includes vetting, eligibility to work, safeguards our employees against human trafficking or individuals being forced to work against their will.
• Code of Conduct– Our code defines the objectives and rules that reflect our commitment to responsible, ethically irreproachable and legally compliant behaviour from all employees and contractors.
• Whistleblowing policy– where there are concerns regarding any unethical conduct within our business, including any forms of modern slavery, we strongly encourage our employees to report the concern so we may properly and quickly resolve the situation. An external and independent whistleblowing hotline service operates 24 hours a days 365 days a year, across approximately 40 countries enabling our employees to report matters anonymously, without fear of reprisal and includes a translation service.

Our Suppliers

The Group works with a wide and varied network of suppliers to execute and support solutions that we design for our clients. Supplier due diligence is a critical part of what we provide for our clients and essential for the security and performance of our own business.

All suppliers to the Group must go through our due diligence process at the on-boarding stage and are then subject to regular audits and reviews. These audits are based on perceived risk (i.e. country of supplier, strategic importance of supplier, and handling of confidential data) with a tiered approach taken to ensure each supplier’s corporate social responsibilities are aligned with that of the Group and, most importantly, United Nations Global Compact, the UN Universal Declaration of Human Rights as well as the 1998 International Labour Organization Declaration on Fundamental Principles and Rights at Work in addition to full compliance with the UK legislation, including the Modern Slavery Act.

Our Supplier Code of Conduct sets the minimum standards for doing business with the Group, and we request is signed by each supplier as part of the onboarding process, with follow up to ensure our policies are adhered to. We also review supply chain contracts to ensure they contain the appropriate legislative requirements.

Breaches of our code and/or the Modern Slavery Act within our supply chain are treated seriously and investigated in detail. Whilst we shall, of course look to support companies in their efforts to comply with the legislation, in the event of a serious breach, a termination of the supplier relationship could occur.

Key Performance Indicators

We will know and understand the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

• No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified; and by
• Completing annual due diligence, where necessary, on our supplier’s code of conduct.

Looking Forward

We will periodically review the effectiveness of our processes and systems and any changes will be reflected in future annual statements.

Globally, the Group’s employees have participated and volunteered across a wide range of charitable initiatives including 22,000 hours for employee paid volunteer day incentive globally, Ukraine crisis fundraising, sponsoring POPAI’s Retail Recycling Research, Alexandra Murphy HHT Foundation, Pencils for Kids, World Vision India sponsoring a child, fundraising for Epilepsy Society and Alzheimer’s Society and many other charities, all aiding the underprivileged in the community.

Annual Report and Financial Statements (31 December 2022)