Modern slavery and human trafficking statement 2017
ITN (Independent Television News Limited) recognises our legal and moral obligations to comply with the UK’s Modern Slavery Act and we are committed to running our operations responsibly. The Act defines modern slavery as “slavery, servitude, and forced or compulsory labour” as well as “human trafficking”. We are committed to ensuring that slavery, human trafficking, and child labour – indeed, any abuse of human rights – have no place in or around our organisation, and are pleased to reinforce that commitment through this statement. We believe that a structured and controlled approach to managing our supply chain is paramount in ensuring we are able to continue to be one of the leading production companies in the UK and around the world. We comply with all applicable employment legislation relating to employee terms and conditions, including pay, and we invest heavily in supporting the health and wellbeing of our staff. Within the UK, nobody who works in our offices – whether directly employed or not – earns less than the Living Wage, and we are proud to be Principal Partners of the Living Wage Foundation, encouraging others to adopt this important commitment to fair pay.
This statement endorses the United Nations Guiding Principles on Business and Human Rights and supports the principles contained within the International Bill of Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work.
Business structure, operations and supply chain
ITN is the UK’s biggest independent producer of commercial news programming, producing the award-winning ITV News, Channel 4 News and 5 News. Our independent production company ITN Productions produces television programmes, films, sports content, industry programming and commercials. Supporting these functions are technical support, human resources, finance, communications and legal teams. There are a variety of employee types from full-time office-based staff to UK-based freelancers and part-time stringers based where stories are breaking around the world. Due to the nature of the work, ITN operates on a global platform with a dynamic workforce.
ITN seeks to partner with suppliers that adopt the same strict standards that we do. We expect our suppliers to operate fair and ethical workplaces and practices, where workers are treated with dignity and respect, and the highest standards of human rights are upheld.
In the event that we become aware of a case of modern slavery occurring within our supply chain, we will work with the supplier to implement remedial action. In all cases consideration will be given to the approach that produces the safest outcome for potential victims of modern slavery.
We expect our suppliers to engage with us constructively and responsibly, and to demonstrate their willingness to remedy issues in a timely manner. ITN reserves the right to refuse to partner with suppliers that do not achieve or are unable to demonstrate progress towards the eradication of modern slavery within their organisations and/or supply chains.
Over five years ago ITN developed a number of policies which are relevant to the modern slavery agenda. Though not specific to modern slavery and human trafficking, these set out our expectations of employees and the responsibilities we place upon ourselves to ensure good and ethical business practice. Below are extracts from three policies which demonstrate ITN’s intolerance of any form of modern slavery or human trafficking.
Grievance: ‘It is ITN’s desire to ensure that employees with a grievance relating to their employment can follow a procedure that aims to resolve their grievance as quickly, consistently and as fairly as possible.’
Diversity and Equality: ‘We value having a diverse workforce and believe every employee should be treated fairly and with respect and be given the opportunity to develop their full potential regardless of race, disability, age, colour, ethnic or national origin, sex, marital status, family status, sexual orientation, religion or belief.’
Fairness and Dignity: ‘All employees have a right to work in an environment free from harassment and bullying. ITN is committed to working towards creating a working climate in which all employees are treated fairly and with dignity and respect. We will take action to identify and eliminate any directly or indirectly discriminatory practices which act as barriers to achieving this objective. It is the responsibility of every employee to ensure that this policy is active within the workplace and everyone can work without fear of bullying or harassment. Line managers have particular responsibility for implementing this policy and ensuring they promote a harmonious working environment for all.’
ITN commits to developing a modern slavery policy in 2018 to specifically outline the actions it is taking to rule out modern slavery and human trafficking in its supply chain. As part of this, ITN commits to putting in place a modern slavery whistleblowing facility, to help eliminate modern slavery and human trafficking from its operations.
ITN has developed a risk-based approach to assess the likelihood of the existence of modern slavery within our supply chain. We retain a firm of specialist consultants to assist us with this task. This first risk assessment has been a high level exercise, simply including the largest (in terms of spend) tier 1 suppliers from ITN’s core operations. These suppliers were then categorised based on their sector and country of operation. Countries were categorised as high, medium or low risk in accordance with the Global Slavery Index’s rankings, and ranked in the same way for sector risk based on our consultant experts’ experience. The sector and country risks were then merged into a matrix which highlighted the key risk suppliers.
The initial findings from the risk assessment suggest that, whilst ITN’s tier 1 suppliers – part of our core operations – are not particularly high risk from a modern slavery standpoint, our purchase of technology products from providers who source from Asia is one area we need to explore further. Equally there is likely to be higher risk in tier 2 of the supply chain and beyond. In addition, we commission ad-hoc projects and operations in countries that have a relatively high incidence of modern slavery, such as India, and we recognise the need to understand how some of our suppliers and sub-suppliers currently manage this risk.
We commit to improving this risk assessment in future years by extending it to all of our suppliers and where possible to tier 2 and beyond.
Our due diligence processes
We are committed during 2017 to issuing a modern slavery questionnaire to those of our existing suppliers we identified as high risk to assess their current anti-modern slavery policies and controls. When responses are received, they will be evaluated and the risk assessment of the supplier updated accordingly. Where appropriate, suppliers will then be required to develop an action plan to reduce any potential risks of slavery. We will track progress through the agreed deliverables of that action plan. Our modern slavery questionnaire will also be issued to new suppliers of services assessed to be high risk during the on-boarding process.
Key Performance Indicators linked to modern slavery and human trafficking
Key Performance Indicators for 2018 are the following:
- Extend training to all staff and key suppliers via an e-learning exercise to raise awareness of modern slavery and human trafficking and help staff to recognise the signs and mitigate this
- Develop a modern slavery policy outlining ITN’s approach to reducing the likelihood of modern slavery in its supply chain
- Modify our supplier on-boarding process to include safeguards around modern slavery risk
- Develop a due diligence process for high risk suppliers to mitigate risk of modern slavery
Training available to staff
We are currently focusing on raising internal awareness through face-to-face workshop sessions with key managers and personnel involved in procurement in the company to enable the relevant members of our business services team, and specifically our UK procurement, risk, corporate responsibility and human resources functions to understand the requirements of the Modern Slavery Act and to give them the tools to flag and respond to potential issues.
Over time (2017-2018), we will develop a Human Rights e-learning platform for our staff and key suppliers, which will ensure that modern slavery is widely recognised and understood, regardless of staff turnover or changes in the supply chain.
We are committed to working with our suppliers to provide support and guidance when implementing anti-slavery policies.
Chief Executive Officer