UK Modern Slavery Statement 2022

Condé Nast Holdings Limited (formerly Condé Nast International Limited)

The Condé Nast Publications Limited

This statement is made by the UK operations of Condé Nast Holdings Limited (CNHL) and its UK subsidiaries, including The Condé Nast Publications Limited pursuant to section 54(1) of the UK’s Modern Slavery Act 2015 for the financial year ending on 31st December 2022. It is an update to our statement for the financial year ending on 31st December 2021.

Our Organisation

Condé Nast is a global media company home to iconic brands including Vogue, GQ, AD, Condé Nast Traveler, Vanity Fair, Wired, The New Yorker, Glamour, Allure, Bon Appétit, Self and many more. Headquartered in New York and London, the company produces award-winning journalism, content and entertainment for every platform today and operates in 32 markets worldwide including China, France, Germany, India, Italy, Japan, Mexico, Spain and Taiwan.

This statement is written to cover both the operations of Condé Nast Holdings Limited (CNHL) and its subsidiaries, including The Condé Nast Publications Limited (collectively “Condé Nast UK”). References in the statement made to Condé Nast are references to the whole group.

Policies and Procedures

As one Condé Nast, we take our social responsibility extremely seriously. We pride ourselves in respecting the individual no matter what gender, race, nationality, religion or orientation. We are committed to doing business in an ethical way, with honesty, integrity and humanity, and we expect the same from our suppliers and their supply chains.

In 2020, we released a new vision statement, the Condé Code.  As part of that, we made a commitment to six values, including “Earn Trust”.  As stated in the Condé Code “Trust isn’t something we demand. It’s something we earn. We hold the bar high for ourselves to act with respect and integrity in all that we do. When we trust each other, the content, information, and perspectives we distribute shine brighter and travel further. Our audiences can feel it and then they in turn trust us, which is our hardest won and most prized asset.”  Our current Code of Ethical Responsibility emphasises how we work and recognises our commitment to obeying the laws in all the areas in all countries in which we operate. 

The Condé Code and our Code of Ethical Responsibility are underpinned by specific policies. As per our Anti-slavery and Human Trafficking Policy, CNHL has a zero-tolerance approach to slavery and human trafficking of any kind in our operations and supply chain and will take seriously any allegations that human rights are not properly respected.

In 2021,  we launched our Business Principles which provide detailed guidance about how to apply our values to specific issues that may arise in our jobs. The Principles apply to all employees (whether full-time, part-time or temporary) that work for or on behalf of our companies. One of these Principles is “Doing Business in the Right Way” stating Condé Nast takes a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. Details of our Company’s responsibilities can be found in our Anti-slavery & Human Trafficking Policy.

Due Diligence & Procurement

Our Procurement Principles provides guidance to staff on how to mitigate modern slavery risks at all levels of engagement with suppliers.

In 2021, the Procurement and Legal & Policy teams ensured that modern slavery concerns formed part of the contract review process when reviewing applicable third party agreements, including licensee agreements. Compliance clauses, including anti-modern slavery requirements, were included in newly created contract templates and applicable agreements. 

To systemise our due diligence reviews on a wider scale from UK business, we now have a tool to onboard suppliers and vendors that includes due diligence reviews which include Modern Slavery risk assessment.

Risk Assessment

We appointed a global Compliance manager role in our organisation in 2021 who continued to assess the main areas of risk within our business and supply chain, and has summarised the updated results of this assessment below:

Supply Chain Risk Assessment

During 2020, we have been able to analyse and determined that there are a number of core areas of our supply chain throughout our markets where we can work with our existing partners to better understand their approach to modern slavery issues, and, where relevant, how they mitigate these risks within their supply chain. In particular these include:

• Those who print and supply us with paper for our magazines and the labour standards they maintain in their operations and how they address modern slavery risk in their underlying supply chain;

• Those who distribute and licence our magazines and brands and the labour standards they maintain in their operations;

• Those responsible for supplying us with, or procuring the supply of, Condé Nast branded items, and how those products are sourced; and the model agencies and recruiting agencies we hire and the workforce they use to appear and contribute in our magazines;

• Event management and hospitality companies that assist us in arranging and organising events and conferences, and the employees and contractors they use to assist with those events.

Although these are the areas where we consider Condé Nast UK can have the greatest influence over our suppliers’ practices in this area, as part of the new procurement guidelines and Compliance Programme, we plan to consider the modern slavery risks associated with a broader range of suppliers as part of our ongoing procurement guidelines and supplier due diligence procedures and tool, set out further below.

Staff

Employees

Condé Nast UK offers salaries and benefits that meet or exceed regulatory requirements in the relevant jurisdictions. This is supported by our Code of Ethical Responsibility which covers both the ethical responsibilities of the company as well as those of employees. In addition, it also includes specific controls relating to internships, to ensure that interns are paid and treated fairly. This code is available on our website here. As a result, Condé Nast UK believes that the risk of modern slavery occurring within its employee base remains very low.

Contractors

Condé Nast UK regularly utilises agency workers, contractors, consultants or freelancers to support the work that it delivers.  We operate a financial controlling mechanism through our Due Diligence tool; ‘CN OnBoard’ whereby all third parties are required to go through a due diligence check with our internal onboarding tool before they can be paid.  Within this system there are a series of questions which include Modern Slavery.  This onboarding tool enables us to control and assess the risk for Modern Slavery in employing contractors, freelancers, recruiting agencies and model agencies while also ensuring that we comply with legal requirements for contractors by working with an external vendor management company.

Condé Nast UK believes that models or workers in the creative industry under the age of 18 are particularly at risk. To reduce the risk of abuse Condé Nast introduced a comprehensive Code of Conduct for working with models in January 2018. As part of this code of conduct specific restrictions apply to working with models under the age of 18.  

Conde Nast operates an anonymous confidential SpeakUp hotline where our employees, third parties who work with us, contractors etc. may report any suspected violations of our policies or regulations.  Details can be found here; This code is available on our website here.

Training

Following the launch of the Global Business Principles, introducing global policies in 2021, we launched a mandatory Business Principles training for all employees and we continue to push this to new starters through the new joiners onboarding process which ensures that all staff are aware of and comply with the company’s values and policies, including those related to our ethics policies. 

Next Steps

We plan to continue to implement the procurement guidelines and will provide specific training on Compliance and ethical policies to our Procurement team.  Through continued use of our Third Party Due Diligence tool; ‘CN OnBoard’ and our external risk assessment tool, we will continue to risk assess our third parties for International sanctions, Anti-corruption and Anti-Modern Slavery.

Approval

This statement has been approved by the Condé Nast Holdings Limited Board of Directors on behalf of CNHL and The Condé Nast Publications Limited. This statement and CNHL’s approach to the Modern Slavery Act 2015 will be reviewed annually.

The Board of Directors

Jason Miles