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 modern slavery in any form has 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.
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 production division ITN Productions produces television programmes, films, sports content and commercials. Supporting these functions are technical support, human resources, finance, communications and legal teams. ITN has a range of engagement relationships with its workforce 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.
We also expect our suppliers to engage with us constructively and responsibly, and to demonstrate their willingness to address modern slavery-related issues in a timely manner, should such an issue arise. 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.
ITN Modern Slavery Policy
Our Modern Slavery policy specifies the actions we are taking to minimise the risk of modern slavery and human trafficking occurring in our operations and supply chains. It applies to all ITN employees and freelancers. We also expect our suppliers to abide by this policy, as referenced in our standard conditions of contract. Our policy is that we will:
- Aim to prevent and mitigate instances of modern slavery which are linked to our business operations and supply chain
- Identify, understand, and promote awareness of modern slavery issues pertinent to our field of operations
- Address any instances of modern slavery which we find that our business operations have contributed towards
- Comply with the UK’s Modern Slavery Act 2015, including by fulfilling our annual compliance obligations in publishing a ‘Modern Slavery Act Transparency Statement’ for each financial year
ITN’s Modern Slavery policy complements our policies on Grievance, Diversity and Equality and
Fairness and Dignity.
Grievance and Reporting
ITN encourages honest and open communication with all our stakeholders, including those working for us or for our suppliers and those impacted by our operations.
We have recently extended our whistleblowing facility to include modern slavery, thereby encouraging its reporting and prevention in any part of our business and supply chain. If anyone suspects or knows of any modern slavery-related activity, we urge that individual to report it immediately either to their line manager, or anonymously via our online web portal, ‘SpeakingUp’ app or whistleblowing helpline. These services are available for use by all employees to report any instance of unethical behaviour or any suspected instances of modern slavery.
In the event that we become aware of a case of modern slavery occurring within our operations or supply chain, we commit to investigating the cause of the violation so that we can take appropriate steps to prevent a reoccurrence. In any such case, we would prioritise the response that produces the safest outcome for any potential victims.
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.
Our first risk assessment in 2017 included the largest (in terms of spend) tier 1 suppliers to ITN’s core operations. The findings from the risk assessment suggested that whilst ITN’s tier 1 suppliers 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, i.e. in the suppliers to our direct suppliers.
This year, we have improved upon our first risk assessment to extend it to all tier 1 and tier 2 suppliers. We collected information on all tier 1 suppliers, including their sector, country of operation and ITN’s direct spend. This data has been used to estimate the sector and location of tier 2 suppliers using input-output modelling, which measures the flow of spend through the global economy. We then calculated a sector and country risk score for all tier 1 and tier 2 suppliers using a range of indicators, including the 3P Anti-trafficking Policy Index and the Fragile States Index. This has been combined into an overall modern slavery risk score for each supplier.
Our due diligence processes
Using our findings from our first risk assessment in 2017, we issued Modern Slavery Supplier Questionnaires to existing suppliers we identified as high risk to assess their current anti-modern slavery policies and controls. Based on the updated results from the risk assessment this year, we plan to continue to send the Modern Slavery Supplier Questionnaire to new high-risk suppliers and annually review any existing suppliers assessed as high risk. If requested, our suppliers shall provide data to support ITN’s Modern Slavery programme.
Key Performance Indicators linked to modern slavery and human trafficking
The table below outlines our Key Performance Indicators, progress to date and future plans.
||Progress to date
Extend training to all staff via an e-learning exercise to raise awareness of modern slavery and human trafficking and help staff to recognise the signs and mitigate this
||We have developed an e-learning exercise for all staff, which will ensure that modern slavery is widely recognised and understood
||Roll out of eLearning exercise to all staff by mid-2019. Review learning materials to ensure they are up to date and adapt to conform with changes to law and policy
Develop a Modern Slavery policy outlining ITN’s approach to reducing the likelihood of modern slavery in its supply chain
||We have developed a Modern Slavery policy which applies to all ITN employees and freelancers
||This policy will be reviewed and updated on an annual basis to ensure ongoing relevance
Modify our supplier on-boarding process to include safeguards around modern slavery risk
||Standard supplier terms and conditions updated to state supplier obligations to conform to our modern slavery policy
||To continually review integration of our Modern Slavery policy and controls into future improvements to supplier onboarding processes
|Develop a due diligence process for high risk suppliers to mitigate risk of modern slavery
||Due diligence process enhanced as above, improving supplier risk assessment
||Continue to send the Modern Slavery Supplier Questionnaire to new high-risk suppliers and annually assess any existing high-risk suppliers
We have developed an e-learning exercise for all staff, which will ensure that modern slavery is widely recognised and understood within the business. On completion of the e-learn, participants will be able to:
- Explain what modern slavery is and identify the different types that exist
- Understand the UK Modern Slavery Act
- Recognise the signs / indicators of Modern Slavery
- Know what actions to take should instances of modern slavery be witnessed or suspected
This statement has been approved by the Board of Directors of ITN on 27th March 2019. ITN’s financial year ended on 31 December 2018.
Acting Chief Executive Officer