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Modern Slavery Statement 2020

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 2020. It is an update to our statement for the financial year ending on 31st December 2019.

Our Organisation

Condé Nast is a global media company that produces some of the world’s leading media brands including Vogue, The New Yorker, GQ, Glamour, Architectural Digest, Vanity Fair and Wired, among many others. Our colleagues and collaborators bring big ideas to life; intelligent storytelling with a diverse point of view underscores all that we do. Each month our video content generates more than 1 billion views. We reach 83 million consumers in print, 402 million in digital and 474 million across social platforms.

Headquartered in New York and London, Condé Nast operates in 32 markets including China, France, Germany, India, Italy, Japan, Mexico and Latin America, Russia, Spain, Taiwan, the U.K. and the U.S., with additional license partners throughout the world. In addition to the premium content for which we are known, we also produce incomparable experiences and events. Condé Nast Entertainment (CNE) is our award-winning production and distribution studio that launched in 2011. It extends the company’s reach through the development of original content across film, television, social and digital video and virtual reality. In addition, we have ventures in education including the Condé Nast College of Fashion & Design in London, the Condé Nast College in Spain and La Cucina Cooking School in Italy. We also run a world-class hospitality division, which extends to branded products and content.

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”). In August 2018, the company announced that it was merging, to bring ‘Condé Nast’ and ‘Condé Nast International (CNI)’ together. By the end of 2020, this transformation was still continuing. 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. For instance, 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 will be releasing the Business Principles which sets out 5 Principles which govern the way we work and 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” which covers abiding by applicable laws and ethical standards. Following the launch of the Business Principles, the Legal & Policy team will also launch updated policies on different areas of ethics, including a Procurement Policy (the “Compliance Programme”).

Due Diligence & Procurement

We have a London HQ Procurement team which, along with our Legal & Policy team, will have responsibility for identifying and mitigating any issues in the supply chain relating to various areas of risk, to include risks related to human trafficking and the Modern Slavery Act 2015. Our Procurement Policy will provide guidance to staff on how to mitigate modern slavery risks at all levels of engagement with suppliers.

In 2020, 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, we started a project in 2020 to build a new due diligence process whereby modern slavery due diligence is built into new supplier onboarding going forward. As part of the new due diligence process a new supplier onboarding system will be deployed in order to review modern slavery risk across our suppliers.

Risk Assessment

In line with the plan to introduce a new Compliance Programme, we further assessed the main areas of risk within our business and supply chain, and have summarized the updated results of this assessment below:

Supply Chain Risk Assessment

During 2020, we gathered further information about our supply chain and the supply chains of our global organization. We also took steps to better understand the policies and procedures we had in place across our business that are relevant to mitigating these risks. Based on this information we have determined that there are a number of core areas of our supply chain 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 our magazines and the labour standards they maintain in their operations;
  • Those who distribute our magazines and the labour standards they maintain in their operations;
  • Those who supply us with paper for our magazines, and how they address modern slavery risk in their underlying supply chain;
  • Those responsible for supplying us with, or procuring the supply of, Condé Nast branded items, and how those products are sourced; and
  • 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 Policy and Compliance Programme, we plan to consider the modern slavery risks associated with a broader range of suppliers as part of our new procurement policy and supplier due diligence procedures, set out further below.

Staff

Employees

From January - March 2020, the majority of the employees of Condé Nast UK were office-based. From mid-March through to the end of 2020, the majority of the employees of Condé Nast UK worked remotely from home as a result of the Covid-19 pandemic. The majority of the employees of Condé Nast UK were employed on service contracts in accordance with all local legislation and requirements. 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 is very low.

Contractors

Condé Nast UK regularly employs models and other contractors in all jurisdictions in which the group operates. In the past, some models in the fashion industry have been victims of abuse because of lack of regulation, or power imbalances between models and photographers and/or publications.

Condé Nast UK believes that models 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, and we have an anonymous reporting procedure for any suspected violations. This code is available on our website here.

Key Performance Indicators

As part of our Procurement Policy and Compliance Programme rollout, Condé Nast UK is developing ways to assess the effectiveness of the steps it has taken to combat modern slavery. These are likely to include a review of existing suppliers to determine those which present the greatest risk of modern slavery whether because of the jurisdiction in which they are based or the services that they provide.

Training

In 2020, we worked on developing a new training programme related to our new Business Principles, launching in 2021, which will ensure that all staff are aware of and comply with the company’s values and policies, including those related to our ethics policies. Once the updated ethics policies are launched, enhanced training will be given to those persons who deal with suppliers and senior leadership in higher risk geographical regions to ensure they are able to fully implement Condé Nast’s policies and values.

Next Steps

During 2021, with the further development of our Procurement Policy and Compliance Programme, we will continue to develop our procedures to address Modern Slavery Risks in our supply chain, to include the release of:

  • the new Business Principles;
  • a new suite of Ethics Policies, to include an updated Anti-Human Trafficking and Modern Slavery Policy; and
  • procurement principles to apply across our organisation, and a new supplier onboarding tool, which will address, amongst other areas of risk, modern slavery risks in our supply chain.

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