Modern Slavery Act Statement 2017

Modern Slavery and Human Trafficking Statement for the Financial Year 2015-2016

INTRODUCTION FROM THE CHAIRMAN OF DC THOMSON & COMPANY LIMITED

The DC Thomson group of companies takes its social responsibilities very seriously and conducts its business in accordance with its core values of integrity, respect, commitment and creativity. However business practices can always be improved and we are therefore committed to understanding more about modern slavery and improving our practices to ensure that slavery and human trafficking are not present in our business or supply chain.

Our Group’s Organisational structure:
DC Thomson is a private company that heads up one of the leading media organisations in the UK operating under a portfolio of well-known brands. It is headquartered in Dundee, Scotland, with group trading companies located across the UK and in the USA, Australia, India and Hong Kong. The Group produces high quality traditional and digital publications that are distributed around the world, as well as offering cloud hosting facilities and technological solution services, entertainment and retail services and has a corporate ventures arm.

This statement is made on behalf of the following UK-based group operations Parragon, Wild & Wolf, Shortlist, Puzzler Media Limited, FindMyPast, Brightsolid Online Technologies Limited and Beano Studios Ltd, but all principles, policies and processes are or will be disseminated to its overseas group companies.

OUR SUPPLY CHAINS
We procure a wide range of goods and services from a variety of suppliers. Our supply chains currently support the following activities:
• Printing and publishing
• Print distribution and logistics
• Product manufacture and import
• Retail services
• Recruitment and training
• Advertising and marketing
• IT services
• Operations and infrastructure support
• Business process outsourcing

We have adopted a risk-based approach to the assessment of our business and supply chain, which has involved taking geographical, industry and market factors into account in order to identify categories of supply that may present a higher risk of modern slavery being present. We are focusing our attention on suppliers in these categories areas initially, though any resulting policy changes will extend to the whole business.

ACTIONS TO ADDRESS RISK
As part of our initiative to identify and mitigate risk we have undertaken, or are in the process of undertaking the following actions:
• introducing contractual obligations that reflect modern slavery legislation across our suite of standard terms and bespoke contractual arrangements
• building the assessment of slavery and trafficking risk into our supplier sourcing, due diligence and on-boarding programmes
• reviewing and assessing existing suppliers, and in particular their sourcing policies in key risk areas;
• assessing whether a formal Supplier Code of Conduct would be an effective tool in areas of the business where a modern slavery risk is identified.

We have historically favoured suppliers that operate under recognised ethical codes of conduct that include regular compliance audits and we only work with companies that contractually commit to complying with applicable laws and regulations.

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. To this end, in addition to reviewing and updating all policies that touch on identified areas of risk, we are developing a stand-alone anti-slavery policy that will reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. This policy will be owned and administered by DC Thomson’s Corporate Secretary.
Primary responsibility for identifying risks and implementing process around prevention of modern slavery in our supply chain will lie with our procurement and sourcing functions within each operation. In addition DC Thomson has a compliance oversight group that is a Board committee independent of the operation of the business and a dedicated compliance team, which consists of representatives from the legal, HR, procurement and operations departments.

FURTHER STEPS
During the next phase of our programme we intend to take the following additional steps:
• Dissemination of an anti-slavery and human trafficking policy throughout the group
• Implementation of processes for identifying, assessing, mitigating and reporting specifically on modern slavery risks in the business;
• Development and implementation of staff training;

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year 2015 – 2016.