Transparency in Supply Chains
Policy Statement
Modern slavery is a crime and a violation of fundamental human rights. Slavery can take many forms, including servitude, forced or compulsory labor and human trafficking, all forms of slavery share the common characteristic of deprivation of a person’s liberty by another to exploit them for personal or commercial gain.
Teneo is committed to acting ethically and with integrity in all our business dealings and relationships and seeks to ensure modern slavery is not taking place anywhere in our business or supply chains.
We have a zero-tolerance approach to modern slavery and human trafficking in our business and expect the same high standard and commitment from all contractors, suppliers, business partners and clients. We are committed to implementing and enforcing effective systems and controls to ensure this is the case. We will uphold all laws relevant to countering modern slavery in the jurisdictions in which we operate, including the Modern Slavery Act 2015.
Scope
This policy applies to all personnel working with and for Teneo in any capacity, including Teneo personnel at all levels such as officers, directors, employees, agents, seconded employees, interns as well as contractors, consultants, suppliers, and business partners.
Contractors, suppliers, business partners and clients of Teneo will be notified of this Policy in the course of contracting or through their business relationship.
This policy does not form part of an employee’s contract and we may amend it at any time.
Responsibility for the Policy
Management at all levels are responsible for ensuring those reporting to them understand the issue of modern slavery in supply chains and comply with this policy.
Compliance with this policy
You must read, understand, and comply with this Policy. If you have any questions concerning this Policy you should raise them with a member of Teneo’s legal department.
The prevention, detection and reporting of instances of modern slavery in any part of Teneo’s business or involving its contractors, suppliers, business partners and clients is the responsibility of all those working for Teneo or under Teneo’s control. You must avoid any activity that might lead to or suggest a violation of this Policy.
You must immediately report any conduct you believe may have violated this Policy to your supervisor or to a member of the legal department. You are encouraged to provide notification of any suspicion or concern in this regard at the earliest stage and at your earliest opportunity.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring that no one suffers any adverse or detrimental treatment as a result of reporting in good faith their suspicion that modern slavery if whatever form is or may be taking place in any part of the Teneo business or any of Teneo’s supply chains.
Breaches
Teneo employees that violate this Policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. Failing to report an instance of slavery of which you become aware may also become grounds for disciplinary action.
Teneo may terminate its relationship with individuals and organisations working on our behalf if they breach this policy.
This statement is published on behalf of Teneo Business Consulting Limited, Teneo Financial Advisory Limited, Teneo Strategy Limited, Ridgeway Partners Limited t/a Teneo People Advisory, Tulchan Communications LLP and Vox Media Limited (“Teneo UK”) pursuant to section 54 of the Modern Slavery Act 2015. It constitutes our modern slavery and human trafficking statement for the financial year ending 31 December 2023.
Introduction
Teneo is committed to conducting business in a responsible and ethical manner. We have a zero-tolerance approach to modern slavery and human trafficking in our business and expect the same high standard and commitment from those we do business with. Teneo acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the Modern Slavery Act 2015.
About Teneo
The Teneo UK companies are part of Teneo, a global CEO advisory firm that provides providing comprehensive strategic advisory services that address complex business and reputational challenges. Further information on the services that we offer is available here.
As a professional services firm, we consider the risk of modern slavery existing within our business to be low but as part of the firm’s ethical approach, we believe that each of us has a responsibility to identify and confront modern slavery and human rights violations.
Our Supply Chains
Teneo UK’s supply chains relate to our business as an advisory firm. These supply chains include supplying personnel, goods and services to support the advisory services we provide to our clients. We have considered our supply chains and due to their size and nature we have concluded that they are largely low risk in relation to slavery or human trafficking both in our own business and with regard to our supply chain. We recognise that some suppliers such as catering services involve a potentially higher risk.
In engaging with suppliers, we work with companies where we have experience of the quality of their service, ethics and ways of working either directly or through recommendation from trusted third parties. We maintain a database of trusted and preferred suppliers and always seek to ensure the quality of our suppliers and mitigate risk from harmful working practices.
We remain committed to ensuring that all our people, including on site contractors are paid fairly. We adhere to a Living Wage Policy for our direct employees and those suppliers who are frequently working on our premises.
Our policies on slavery and human trafficking
In line with our values and business processes many of our existing policies and procedures are relevant to ensuring that there is no slavery or human trafficking in our business or supply chains; Code of Conduct and Ethics, Diversity and Inclusion Policy, Corporate Social Responsibility Policy and Quality Assurance processes (“Teneo Policies”).
An Anti-Slavery policy to help educate employees on modern slavery and what they should do if they suspect incidents of slavery was implemented in 2019. All employees receive a copy of our employee handbook on joining and are asked to sign to confirm that they have read and understood the policies. Any breach of our policies is taken very seriously and can result in disciplinary action, up to and including dismissal.
Our approach to combatting modern slavery in the last financial year
Teneo’s internal policies and procedures aim to ensure that effective systems and controls are in place to prevent slavery and human trafficking from occurring in any part of our business. Teneo’s Policies set out how we deal with our clients, employees and the public and we promote a working environment that encourages everyone to express their concerns about behaviour or decisions that they perceive to unethical or of concern. We have a global whistleblowing policy, and all employees can access an independent whistleblowing hotline. We have systems in place to protect whistle blowers.
A Supplier Code of Conduct is in place and suppliers and vendors are required to adhere to this as part of their procurement contract with us. This Code of Conduct sets out clear standards of business conduct and ethics that our suppliers must abide by and is published on our website.
The obligations set out in the Supplier Code of Conduct are strengthened by our standard contract terms which require compliance with the Modern Slavery Act and other applicable legislation which provide Teneo with the right to terminate the agreements by written notice in the event of a material breach that cannot be remedied.
Teneo is a signatory to the U.N. Global Compact and in doing so confirmed its support for internationally accepted principles regarding human rights, labour standards, the environment and anticorruption.
During the FY2023, no complaints or concerns were raised about modern slavery or human trafficking taking place in our business.
Looking Ahead
Over the course of the next financial year we will continue to enhance our procedures to help us identify, prevent and mitigate any risks of modern slavery or human trafficking in relation to new and existing suppliers. Mandatory training for all employees on Modern Slavery risks will be implemented in 2024.
This statement was approved by the boards of the Teneo UK entities and signed by Leo van der Borgh, Director.
28 June 2024