Modern Slavery Statement

Overview

Introduction

The following statement has been prepared in fulfilment of Gravity Global’s (Newton Topco Limited and its subsidiaries) obligations under the Modern Slavery Act 2015. This statement covers the financial year 2023 and describes our commitment and steps taken to mitigate modern slavery in our business and supply chain.

About Us

Gravity Global is a marketing consultancy specialising in brands operating in complex markets. Led by strategy, innovation, technology, data and creativity, we create brand-to-demand marketing programmes that drive transformational growth for our clients.

We specialise in working with brands operating in sectors undergoing disruptive change and brands that make a positive impact on our world’s future - by giving them the attention they need to grow, and influencing them to say, do, and be better. We also provide pro bono creative services to charitable organisations.

Respect for human rights is a fundamental principle for Gravity Global and we do not tolerate any form of modern slavery or human trafficking in any part of our business. We are committed to embedding the principles of the United National Global Compact in relation to human rights, labour, environment and anti-corruption in our business.

We recognise that modern slavery exists in the countries in which we operate, and we acknowledge the important role that Gravity Global has to play in combatting exploitative labour practices from our operations and supply chain.

Our Operations

Gravity Global and its subsidiaries employ 500 people across the globe. We are headquartered in London. As skilled professionals within the advertising, marketing and communications services sector – being victims of modern slavery is low. Nonetheless, we operate in countries with differing records and risk profiles on modern slavery and hence we take our commitments in this area very seriously.

Review

This policy is subject to an annual review to ensure its continued fit to the business and industry best practice. Additional reviews may be triggered as part of incident response assessments. Any review dates and associated modifications must be documented in the 'Review and Change Record' section of this document.

Monitoring and Enforcement

The policy requirements are monitored by the Compliance Team. Non-compliance with the Policy Requirements will result in proportionate and appropriate action being taken. Such action may encompass warnings, suspension, termination of employment/contract, legal action, and civil or criminal charges, as applicable.

Our supply chain

Gravity Global is committed to creating an inclusive, sustainable, ethical and diverse network of business-enabling suppliers.

Due to the organisational structure of the business and wide range of services on offer, we have a complex supply chain to manage. We work with more than 2,000 companies across our supply network.

Our suppliers fall into two main categories: those providing goods and services used to run our companies such as IT, travel, telecommunications, professional services and facilities; and those used in client work, such as advertising production and market research.

Risk assessment

We assess supply chain risk based on country, industry, and procurement category.

Within the category assessment, we consider several high-risk factors linked to human capital, especially the recruitment and employment of low-skilled labour, migrant labour and contractors.

In 2023, we began an extensive transformation programme to modernise our procurement ecosystem and infrastructure and optimise how we buy. Workstreams include the roll out of a global supplier portal across all markets by the end of 2024 and standardising processes and systems. The program is being led by our Chief Financial Officer and Operations team, with support from Gravity Global’s Group sustainability committee, to embed the new controls and processes that are critical to a robust and responsible sourcing programme.

Due diligence in our supply network

Our expectations of suppliers are set out in the Supplier Code of Conduct and are based on the Gravity Global Business Code of Conduct which applies to employees.

During supplier selection and before Gravity Global enters into a commercial agreement, the finance and operations team will require that suppliers sign ‘Gravity Global’s Business Code of Conduct – Supplier Version’, confirming they will comply with our standards or demonstrate that they have the equivalent standards in place.

These standards include requirements relating to human rights, including modern slavery issues such as child, forced or bonded labour), as well as labour practices (such as anti-harassment and discrimination, and health and safety), social impacts (such as anti-bribery and corruption) and other sustainability issues.

Our Code requires suppliers to apply similar standards to companies within their own supply chain, including evidencing diversity and social responsibility in their cultures, behaviours and attitudes.

Gravity Global reserves the right to terminate its contract with any supplier found to breach or fail to comply with, any legislation relating to modern slavery.

Our policies

We do not tolerate any form of modern slavery or human trafficking in any part of our business. Gravity Global is committed to tackling the risk of modern slavery from our supply chain and operations at a global scale.

Gravity Global views this as an important component of our obligations to support the basic human rights of our people and their families, including the right to fair conditions of work, freedom from forced labour and child labour. We outline this commitment and set clear ethical standards for our people and companies through our policy frameworks.

Our Business Code of Conduct outlines how we are committed to acting ethically in all aspects of our business and to maintaining the highest standards of honesty and integrity. We specifically reference the Modern Slavery Act to highlight how seriously we take this issue. All of our people are required to uphold our Business Code of Conduct.

Our Business Code of Conduct – Supplier Version sets out our expectations of suppliers and is based on the Gravity Global Code of Conduct that applies to all our companies and people. The supplier version includes requirements for labour practices (such as anti-harassment and discrimination, and health and safety), human rights (including no child, forced or bonded labour), and social impacts (such as anti-bribery and corruption) as well as other sustainability issues.

Gravity Global’s code of Conduct is set within a wider ethical framework, which includes our Human Rights Policy. Our Human Rights policy reflects international standards and principles including the International Bill of Human Rights, the UN’s Guiding Principles on Business and Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and the Children’s Rights and Business Principles.

In addition, our Sustainability Policy outlines our positive contribution to society and the environment underpinned by our responsibility to respect human rights.

Our Procurement Policy outlines a clear procedure for responsible procurement. This includes the provision that, wherever possible, our companies should use centrally negotiated contracts with approved suppliers for commonly purchased goods and services. Regardless, anyone who buys goods and services in any Gravity Global company should consider sustainability risks and criteria to determine whether suppliers are fit for purpose.

Our Equal Opportunities Policy set out our core principles for responsible recruitment and people management as part of our responsibility to treat our employees with dignity and respect.

Where are we now?

Gravity Global is a dynamic business with ever-evolving business operations and we recognise that there are always improvements that can be made to the way we work. To ensure that our policies are kept up-to-date and compliant with international and national regulatory frameworks we conduct regular reviews.

The application of our policies and procedures is monitored within each company and by the internal audit, legal, business integrity and risk and controls functions. Breaches are investigated by our legal and business integrity teams and, where appropriate, external advisors.

Governance

We have established governance processes and policies to help us manage human rights risks, including modern slavery, consistently across the Company.

Our CFO oversees our approach to ethics and compliance. The Board and Executive Leadership Team provides additional oversight and guidance on any ethical issues that may arise.

The Board, assisted by the Audit and Ethics Committees, has oversight and responsibility for our approach to risk management, and is driven by our risk governance framework, business integrity programme, culture based upon the principles set out in our Code of Conduct and our internal control frameworks.

Our Board has responsibility for reviewing and considering Gravity Global’s Modern Slavery Statement and sustainability-related policies, including the Company’s Human Rights Position Statement, for approval by the Board.

Our policy framework and training set clear ethical standards for our people and agencies. We want to embed a culture of integrity and transparency where our people make the right decisions automatically and instinctively.

The Gravity Global Code of Business Conduct applies to everyone at Gravity Global. It sets out our responsibilities to our people, partners and shareholders to act ethically, legally and with integrity. Senior managers in all our agencies and our businesses are asked to sign a copy of the Gravity Global Code of Business Conduct each year to confirm they will comply with its principles.

Remediation

Our people can report concerns or suspected cases of misconduct confidentially (and, if they wish, anonymously). Our people can also speak directly to our board of directors.

Risk impact from whistleblower reports

All whistleblower reports received by the CFO are handled in line with Gravity Global’s Whistleblowing and Investigations Protocols and logged, investigated and tracked through to a conclusion including any remediation or follow-up actions that might be required.

Reports are also analysed for risk impact and root causes. Learnings generated from this analysis are converted into recommendations including for training sessions, workshops and practical resources and implemented together with the support and input of the Board. Recommended remediation can also include disciplinary action, changes to systems, controls and processes or wider review and monitoring for a particular time period.

The nature of each report, action taken and outcome is reported to the Audit Committee and the approach and process are reviewed by the auditors.

Gravity Global is committed to providing a safe and confidential way for people with genuine concerns to raise them, and to do so without fear of reprisals. Gravity Global does not tolerate any retaliatory behaviour against individuals reporting concerns and is equally committed to preserving the anonymity of an individual who makes a report and does not wish to have their identity revealed.

The consequences of misconduct or retaliation range from individual performance management, training for a business or an office and one-on-one training or coaching for an individual through to staff relocation and staff dismissal.

Training and awareness

All global employees complete mandatory annual training on topics such as equality, diversity & inclusion, bullying & harassment, anti-bribery and corruption, data protection, and information security.

Gravity Global has also issued guidance and training materials on modern slavery for our businesses to communicate to relevant people in their operations, such as HR Directors. The training covers the basic principles of the Modern Slavery Act 2015 and explains what modern slavery encompasses, how to assess risk in different aspects of our business and supply chain, our key policies, and our remediation process.

Collaboration

Gravity Global is committed to working with other businesses and governments to act against modern slavery.