The Condé Nast International Ltd. Condé Nast Publications Ltd.
This statement is made by the UK operations of Condé Nast International Limited (CNI) and its UK subsidiaries, including Condé Nast Publications Limited pursuant to section 54(1) of the UK’s Modern Slavery Act 2015 for the financial year ending on 31st December 2019. It is an update to our statement for the financial year ending on 31st December 2018.
Condé Nast is a global media company that produces some of the world’s leading print, digital, video and social brands. These include Vogue, GQ, The New Yorker, Vanity Fair, Wired, Architectural Digest, Condé Nast Traveler, among others.
Our colleagues and collaborators bring big ideas to life; intelligent storytelling with a diverse point of view underscores all that we do. Each month our video content generates more than 1 billion views. We reach 88 million consumers in print, 427 million in digital and 423 million across social platforms.
Headquartered in New York and London, Condé Nast operates in 32 markets including China, France, Germany, India, Italy, Japan, Mexico and Latin America, Russia, Spain, Taiwan, the U.K. and the U.S., with additional license partners throughout the world.
In addition to publishing 30 brands, we run a world-class hospitality division (which extends to branded products and content), Condé Nast Entertainment, our award-winning production and distribution studio, and have several ventures in education. Committed to reinventing ourselves, we are constantly evaluating how we work across countries and brands and how we develop our products to expand our global leadership in the fashion, entertainment and lifestyle spaces.
This statement is written to cover both the operations of Condé Nast International Limited (CNI) and its subsidiaries, including Condé Nast Publications Limited. In August 2018, it was announced that Condé Nast was restructuring to bring Condé Nast and Condé Nast International (CNI) together. By the end of 2019, this restructure was still continuing. References in the statement made to Condé Nast are references to the whole group.
Policies and Procedures
As one Condé Nast, we take our social responsibility extremely seriously. We pride ourselves in respecting the individual no matter what gender, race, nationality, religion or orientation. We are committed to doing business in an ethical way, with honesty, integrity and humanity, and we expect the same from our suppliers and their supply chains.
Our Code of Ethical Responsibility emphasises how we work and recognises our commitment to obeying the laws in all areas in all countries in which we operate.
As per our Anti-slavery and Human Trafficking Policy, CNI has a zero-tolerance approach to slavery and human trafficking of any kind in our operations and supply chain and will take seriously any allegations that human rights are not properly respected.
In 2019, we began working with an external consultant to design a new compliance programme targeted at various areas of risk faced by CNI, including modern slavery. The framework for this programme has been agreed, and the programme will be gradually rolled out across our organisation.
Due Diligence & Procurement
We have a Procurement Department which, along with our Legal & Policy team, will have responsibility for identifying and mitigating any issues in the supply chain relating to various areas of risk, to include risks related to human trafficking and the Modern Slavery Act 2015.
In 2019, we worked on developing our procurement procedures, in line with our new compliance programme. As part of this process we aim to integrate the following processes into our vendor onboarding going forward:
• incorporation of modern slavery due diligence as part of our procurement procedures; and • incorporation of anti-modern slavery clauses in supplier contracts to help address modern slavery risks.
In line with the plan to introduce a new compliance programme, we further assessed the main areas of risk within our business and supply chain, and have summarized the updated results of this assessment below:
Supply Chain Risk Assessment
During 2019, we gathered further information about our supply chain and the supply chains of our global organization. We also took steps to better understand the policies and procedures we had in place across our business that are relevant to mitigating these risks. Based on this information we have determined that there are a number of core areas of our supply chain where we can work with our existing partners to better understand their approach to modern slavery issues, and, where relevant, how they mitigate these risks within their supply chain. In particular these include:
• Those who print our magazines and the labour standards they maintain in their operations; • Those who distribute our magazines and the labour standards they maintain in their operations; • Those who supply us with paper for our magazines, and how they address modern slavery risk in their underlying supply chain; • Those responsible for supplying us with, or procuring the supply of, CNI branded items, and how those products are sourced; and • Event management and hospitality companies that assist us in arranging and organising events and conferences, and the employees and contractors they use to assist with those events.
Although these are the areas where we consider CNI can have the greatest influence over our suppliers’ practices in this area, as part of the new Procurement programme, we plan to consider the modern slavery risks associated with a broader range of suppliers as part of our new procurement policy and supplier due diligence procedures, set out further below.
During 2019, the majority of the employees of CNI were office-based and employed on service contracts in accordance with all local legislation and requirements. CNI offers salaries and benefits that meet or exceed regulatory requirements in the relevant jurisdictions. This is supported by our Code of Ethical Responsibility which covers both the ethical responsibilities of the company as well as those of employees. In addition, it also includes specific controls relating to internships, to ensure that interns are paid and treated fairly. This code is available on our website here. As a result, CNI believe that the risk of modern slavery occurring within its employee base is very low.
CNI regularly employs models and other contractors in all jurisdictions in which the group operates. In the past, models in the fashion industry have been victims of abuse because of lack of regulation, or power imbalances between models and photographers and/or publications.
CNI believes that models under the age of 18 are particularly at risk. To reduce the risk of abuse CNI introduced a comprehensive Code of Conduct for working with models in January 2018. As part of this code of conduct specific restrictions apply to working with models under the age of 18, and we have an anonymous reporting procedure for any suspected violations. This code is available on our website here.
Key Performance Indicators
As part of our Procurement Policy and Compliance Programme rollout, CNI is developing ways to assess the effectiveness of the steps it has taken to combat modern slavery. These are likely to include a review of existing suppliers to determine those which present the greatest risk of modern slavery whether because of the jurisdiction in which they are based or the services that they provide.
We are introducing a new training programme related to our Code which will ensure that all staff are aware of and comply with the firm’s business principles, including those related to our modern slavery policy, and understand how to identify likely signs of modern slavery and report any suspicions. Enhanced training will be given to those persons who deal with suppliers and senior leadership in higher risk geographical regions to ensure they are able to fully implement CNI’s policies and values.
During 2020/2021, with the further development of our Procurement Policy and Compliance Programme, we will continue to develop our procedures to address Modern Slavery Risks in our supply chain, to include: • the implementation of a new anonymous whistleblowing hotline; • development of a suite of Ethics Policies, to include an updated Anti-Human Trafficking and Modern Slavery Policy; • development of a new procurement policy to apply across our organisation, which will address, amongst other areas of risk, modern slavery risks in our supply chain; and • the introduction of supplier due diligence procedures, bespoke risk assessment tools and anti-modern slavery clauses to address the risk of modern slavery within our supply chain where appropriate.
This statement has been approved by the Condé Nast International Limited Board of Directors on behalf of CNI and Condé Nast Publications Limited. This statement and CNI’s approach to the Modern Slavery Act 2015 will be reviewed annually.