INTRODUCTION

At dentsu we believe we must be a force for good. Our purpose: 'an invitation to the never before' and vision: 'to be at the forefront of people-centred transformations that shape society', form the cornerstone of our value creation model, underpinned by our commitment to respect human rights and protect the interests of our employees and value chain.

Dentsu operates according to established principles of good governance and is committed to conducting business with integrity and to the highest ethical standards.

As such, dentsu has zero tolerance of modern slavery and human trafficking in any form and is committed to doing all it can to ensure no form of slavery or human trafficking exists within its value chain.

ORGANISATION STRUCTURE

Our business

Dentsu International Limited ("dentsu") is a subsidiary of Dentsu Group Inc and is the London based holding company for the dentsu business which specialises in providing media, customer experience management and creative services.

This business includes Dentsu UK Limited, Merkle Marketing Limited and their associated UK based subsidiaries and brands (together known as "dentsu UK"). Dentsu UK is headquartered in London, with local offices in Manchester, Leeds, Edinburgh, Belfast, Newcastle and Stafford.

In 2023 dentsu completed the acquisition of the TAG group. The TAG group produces a separate statement in accordance with section 54(1) of the UK Modern Slavery Act 2015 which is available here: https://www.tagww.com/modern-slavery/

Supply chain

As a media, digital and creative services provider, dentsu suppliers include but are not limited to:

• media partners;
• IT services and equipment providers;
• printing and production suppliers;
• photographic and other creative services suppliers;
• facilities management and office suppliers;
• catering suppliers; and
• travel services suppliers.

Governance

The respect for human rights underpins our purpose, vision, and value creation towards the realization of the society we aspire to create. It has senior sponsorship, with our Global Chief Governance Officer overseeing our Group human rights program and our Heads of Human Rights responsible for overseeing day-to-day implementation.

Human Rights is a standing agenda item at the Executive-level Group Sustainability Committee which meets four times a year.

Our Heads of Human Rights work closely with our Global Functions teams - including Human Resources, Legal & Compliance, Procurement, Communications, and Brand Assurance - to embed human rights' considerations, provide expertise, and build capacity for the day-to-day management of human rights' risks. This includes various training initiatives including online content, and function/practice-specific workshops, to consultation from internal expertise.

In our international operations, human rights considerations are also represented at each functional working group - including the Legal & Compliance Sustainability Working Group, the Sustainable Procurement Working Group and the Policy Working Group.

Dentsu's Global Procurement Director oversees the Procurement Operations Team, responsible for supplier risk management and sustainable procurement. The Head of Human Rights meets monthly with the Group Procurement Working Group.

POLICIES

Dentsu remains committed to working within applicable laws and as the Act is an integral part of the UK legal framework, its requirements are reflected in the dentsu global policies. These policies set out dentsu's commitment to comply with the Act and the expectations it imposes upon its supply chain and their respective procurement functions, to ensure their own compliance with the Act.

The policies that incorporate the values and objectives of the Act are as follows:

• The Global Code of Conduct - dentsu is committed to conducting business with honesty and integrity and upholding high standards to protect the interests of its employees, clients, shareholders, stakeholders and communities in which they work.

The code explicitly refers to our commitment to honour internationally recognised principles of human rights and comply with applicable employment legislation, our zero-tolerance approach to all forms of slavery including child labour, and our commitment to employ fair and transparent procurement practices.

All employees are required to behave consistently with the Code of Conduct and receive annual training.

• The Group Human Rights Policy - is publicly available on the dentsu website and sets out our commitment to embedding respect for human rights across our operations, defining the minimum expectations that everyone working for and with dentsu, must comply with.

The Policy explicitly states that 'We have a zero-tolerance approach to all forms of slavery and a commitment to comply with applicable employment and human rights legislation, including relevant child labor laws. We require the same from our partners'.

• The Group Supplier Code of Conduct -is publicly available on the dentsu website and clearly states that dentsu's suppliers must conduct their business with honesty and integrity, upholding dentsu's high standards to protect their employees and workers.

The Code explicitly states that suppliers must comply with applicable employment and human rights' legislation and must have zero tolerance of modern slavery and human trafficking, included forced, bonded or compulsory labour.

Suppliers must ensure that all employment is voluntary, and workers are not subject to forced labour or any form of involuntary servitude.

Employees must have the freedom to terminate their employment in accordance with applicable laws and regulations.

Suppliers must not require employees to lodge deposits of money and shall bear all costs related to the recruitment process. Suppliers must not require employees to surrender any formal identification as a condition of employment.

Suppliers must provide all employees with a written employment agreement in a language that they can understand, containing clear terms and conditions of employment.

• Global HR Policy - This details dentsu's commitment to uphold fair employment practices and observe the laws that pertain to, among others, the prohibition of forced, compulsory and child labour and the laws relating to the elimination of any improper treatment or discrimination of employees.
• Global Speak Up Process - dentsu encourages employees to raise, in confidence, any concerns they may have about a suspected wrongdoing in the workplace which includes any concerns regarding the risk of modern slavery or human trafficking.

The externally operated Speak Up portal is free to use, confidential and available 24/7 to all employees and suppliers. We have a zero-tolerance policy against retaliation of any kind against individuals who speak up in good faith.

SUPPLIER DUE DILIGENCE

Unless otherwise stated, this statement refers to Dentsu UK.

As part of the dentsu supplier onboarding process, new suppliers are required to certify their compliance with the Group Supplier Code of Conduct and respond to compliance questions directed at labour practices. This is to ensure that dentsu only engages with those suppliers who share and are fully aligned with its values and principles.

Since 2019, dentsu's standard supplier agreement templates have also included modern slavery and human trafficking warranties and undertakings, which dentsu continues to review and strengthen where necessary. Pursuant to these terms, dentsu makes it incumbent upon its suppliers to respect and comply with all applicable laws, including the Act, and dentsu reserves the right to terminate its commercial partnership with any supplier who is found to be in breach of, or who fails to comply with the Act. This applies to both domestic and international suppliers contracting with dentsu.

EVALUATING EFFECTIVENESS

The effectiveness of the steps taken by dentsu to prevent modern slavery and human trafficking taking place in any part of dentsu's business and within its supply chain will continue to be measured by the following key performance indicators (KPIs):

• number of instances of modern slavery and human trafficking identified as part of the dentsu supplier due diligence process; and
• number of instances of reports being received from employees, the public or law enforcement agencies that modern slavery and human trafficking practices have been identified within the dentsu business.

NEXT STEPS

The activities and efforts described above reflect dentsu's ongoing efforts to ensure there is no modern slavery or human trafficking in its supply chain. It intends to continue to review and monitor and, where necessary, enhance its systems, policies and procedures, as well as improve its training and communications about the Act across the business.

DECLARATION

This statement is made in accordance with section 54(1) of the UK Modern Slavery Act 2015. This statement has been approved by the Dentsu International Limited Board of Directors and constitutes dentsu's modern slavery and human trafficking statement up to the date of publication of this Statement.

Arinobu Soga

Global Chief Governance Officer & Global Chief Financial Officer 12 December 2024