Modern slavery act 2021
This is Kantar’s second Modern Slavery Act statement since the divestment of Kantar from WPP, in line with the UK Modern Slavery Act of 2015. It covers the financial year to December 2021, and describes our commitment and steps taken to prevent any form of modern slavery or human trafficking in both our business and our supply chain.
The scope of this statement is the following entities: The Kantar Group Limited, Kantar UK Limited, Lightspeed Research Ltd and Kantar Media UK Ltd
Kantar is a world leading research, data and evidence-based agency providing insights and actionable recommendations to clients worldwide. The group and its companies operate under several brands in over 90 markets throughout the world. In all instances we respect national laws and any other laws with an international reach. We are committed to acting ethically in all aspects of our business and to maintaining the highest standards of honesty, transparency, and integrity.
Our people are skilled professionals and are not from vulnerable groups where slavery is typically a risk. However, as we understand that modern slavery can be found everywhere, we take our responsibilities for the recruitment and wellbeing of people extremely seriously.
Kantar respects human rights in line with UK and international law and does not tolerate any form of modern slavery or human trafficking in any part of our business, including our supply chain. This is consistent with our disclosure obligations under the Modern Slavery Act 2015
1) Our Policies
Our suite of internal and external policies sets out our expectation and requirements for our suppliers, partners, and colleagues. Where we identify that these stakeholder groups do not meet our high standards, we take appropriate action.
We do not tolerate any form of modern slavery or human trafficking in any part of our business. We outline this commitment and set clear ethical standards for our people and companies through our policy framework. This is outlined in our Human Rights and Modern Slavery Policy.
The most relevant policies to support our Modern Slavery controls and processes are:
Human Rights and Modern Slavery Policy – This document outlines the actions we take to support our position on Human Rights and Modern Slavery including the ethical stance which governs our relationships with our people and partners. Our aim is to review both policies in line with our commitment to preventing modern slavery in our business.
Supplier Code of Conduct – This covers all suppliers that transact with Kantar and is signed by the supplier as part of the supplier onboarding process. This includes the ethical conduct and expectations of our suppliers with regards to their engagement with Kantar covering human rights, modern slavery and the environment. This also includes a declaration that suppliers are compliant with the Modern Slavery Act and confirmation that child labour is not present in their business.
Kantar Business Principles – This sets our minimum expectations and responsibilities for all Kantar colleagues including contractors and affiliate companies. It is a framework to ensure we behave ethically, and includes commitments on human right and sustainability.
Right to Speak
Kantar operates a global, 24 hour “Right to Speak” service through a market leading independent 3rd party supplier, Navex. The service is available in multiple languages and is staffed by appropriately trained, local language speaking individuals. We encourage our staff to raise any concerns they have about the way that Kantar operates and conducts its business, or about any potential breaches regarding danger or wrongdoing. This keeps us all accountable and helps us continually improve our business and our culture. Reports of any actual or suspected violations can also be made on an anonymous basis.
Procurement Policy (& associated Source to Pay Policy)
Our Procurement policy sets out how we approach sourcing and contractual arrangements with suppliers, including our delegation of authority, Kantar contractual terms and use of preferred and approved suppliers. This also includes supplier decommissioning where suppliers are identified to not adhere to any of Kantars compliance policy areas. Furthermore, the policy identifies the Procurement function commitments to manage risk, conduct activity with integrity and support Supplier Diversity.
2) Our Processes
We continue to assure that our controls framework operates effectively and developed our approach to identifying and remediating risks as we deploy market leading tools across our source to pay processes (which currently cover 56% of global spend and will cover 87% by the completion of the programme)
Reducing and Managing Risk
We work with circa 11,500 suppliers across our global supply chain (1,100 in UK) and our aim is to select partners that meet high standards on ethical business conduct, employment practices, human rights, and their approach to diversity and the environment.
We recognise that risk to Human Rights can originate from any part of a supply chain and monitoring it is critical for all stakeholders. However, some areas of our business are more prone to inherent risk than others, so we are developing a framework to identify these areas to focus our reviews and ensure that these risks are addressed and remediated.
Our strategy to mitigate these risks span across different parts of the operating process.
Supplier Compliance Management
We have a rigorous supplier selection process, which focuses on actively de-risking our existing supply chain. This has been supported by the deployment of Coupa Source to Pay tool in 9 markets (including UK and IreIand). We have designed metrics to demonstrate the spend under Procurement influence and spend under contract, to ensure that key business partnerships are covered under robust legal and commercial frameworks.
We require our divisions and functions to use contracts which have been negotiated or approved by our Procurement function. This is determined by a Supplier Compliance List which is made available to the business and embedded in our systems and Procurement policy, as part of the guided buying process. This enables us to have high standards and consistency across our approach and processes.
We also include a “right to audit” clause in our standard Master Agreement for Suppliers, to ensure we have appropriate flexibility to audit our supplier base where required or where risks persist.
As part of our commitment to acting ethically, we actively refine our policies and procedures to ensure that we act ethically, and in compliance and with respect for human rights. This includes the recently set up Procurement Inclusiveness and Diversity programme to identify and support Small and Diverse suppliers.
Although, these programmes have their own benefits, we think of them as just one part of an effort to work closely with our clients, suppliers, and through industry partnerships allow us to promote our values and to raise awareness about human rights and modern slavery too.
Due Diligence Process and Supplier Onboarding
Kantar has developed a Third-Party Assurance Program to assess the controls environment of third parties.
All new suppliers are required by our UK business to undergo a comprehensive supplier onboarding process managed by a dedicated team, which includes not only financial due diligence but also compliance checks including modern slavery, anti-bribery and corruption, and sanctions. Where appropriate we also use external rating agencies such as Dun & Bradstreet.
If any of this due diligence means that a supplier does not meet the Kantar standards, then Kantar will consider a mitigation action plan or will not proceed with supplier onboarding.
We will continue to further strengthen our due diligence on social sustainability issues, including modern slavery throughout the year. The data generated will help us further focus on areas of risk within our supplier engagement strategy.
In the UK, our employees are subject to HR processes including verifying their right to work and verification of employment history and education. All pre-employment checks are dealt with by our offshore HR Service Delivery Centre based in Porto, Portugal.
For recruitment, we use preferred, diverse, and approved suppliers with strong ethical and contractual frameworks and ensure that our suppliers sign our Suppliers Code of Conduct as part of our onboarding and due diligence process. This is a pre-requisite to work with Kantar.
From 2021 we have commenced working with a management partner for our freelancer and contingent workers which helps manage these suppliers in consistent and process driven way that is co-ordinated by a dedicated contingent worker team.
In 2022, we created an Ethics training package that was delivered to all employees globally via our intranet that focused on both personal and business conduct as well as protecting and promoting human rights. The training will be reviewed in 2023 and will be subject to regular ongoing reviews post 2023. More generally, we provide regular training to our employees through our annual Mandatory Compliance training process. All new joiners will be required to complete this training from Q4 2022.
Topics covered include diversity, modern slavery, human rights, conflicts of interest and avoiding misleading work.
3) Tracking Progress
Our Modern Slavery statement is reviewed and signed off by our executive leadership team. This is after having been reviewed and supported by representatives from Procurement, Compliance, Legal, Internal Audit and HR. This subset of stakeholders will continue to convene and oversee the progress of the Human Rights and Modern Slavery policy and set the approach for compliance across the business. Updates are provided to Kantar leadership via the Risk and Opportunities Committee.
We will measure the success and performance of responsible sourcing activities by tracking Key Performance Indicators (KPIs) and metrics, including spend under Procurement Influence and Spend with Diverse Suppliers. The metrics related to modern slavery programme continue to evolve as we obtain greater visibility of data points as part of the roll out of our Coupa Source to Pay tool in the UK.
Performance During 2021
1) 78% of spend in 2021 managed or supported by Procurement related to our UK entities, which represents $275m of spend across 235 suppliers
2) Implementation of Coupa Source to Contract in four key markets, including UK legal entities, which covers 56% of Kantar spend. This solidifies the due diligence checks and controls performed in these markets, utilising both Coupa Risk Assessment and Dunn & Bradstreet finance and compliance checks
3) Spend with diverse suppliers in the UK increased to 6.3% of third party spend, which is on track to achieve our 2025 target set by Kantar leadership
4) Re-design of Procurement category management planning to include sustainability charter (which includes strategy for People, Planet, Profits). This is required for 100% of our category managers.
5) Kantar achieved a Bronze Accreditation from Ecovadis (www.ecovadis.com) which is a sustainability assessment focusing on four key pillars: Environment, Labour & Human Rights, Ethics and Sustainable Procurement. Our scorecard is available on request.
Modern Slavery Statement
Through the course of 2021, we have not identified or been made aware of any form of Modern Slavery in any part of our supply chain or within our internal processes
Our commitment for the next year
The development of these core principles is a journey and continued discussions, both internally and externally with our supply base, will ensure that we are applying thought leadership and best practice as a Kantar priority.
During 2022 we will focus on the following areas:
- Commitment to increasing our spend under contract to 85% of total third party spend
- 2022 roll out of Coupa Purchase to Pay in UKI and North America markets, which helps enforce Procurement policies and processes around supplier payments, with Germany, France, the Netherlands, Spain and Italy to follow in 2023. After the deployment into these markets, this will cover 70% of spend.
- 2022 Ecovadis accreditation submission, with focus on reporting, detailed action plans and improving on our 2021 score
- Embed supplier diversity as part of our supplier relationship management governance with our strategic technology suppliers.
- Our ambition is for 80% of our colleagues to complete Ethics training that is owned by our Global Head of Compliance with input from Procurement, Legal, HR and Operations.
This 2021 statement was approved by The Kantar Group Limited board on 6 October 2022 and subsequently by each of the subsidiary boards identified within scope above.
Chief Financial Officer and Director
The Kantar Group Limited
11 October 2022