Code of Business Conduct

T&P Code of Business Conduct

The following Code of Business Conduct (“the Code”) has been approved by the Board of Directors of The & Partners Group Ltd (“T&P”), on behalf of all of the agencies in our group (including MSIX Communications Limited, Halpern Limited, Muster Agency Limited, ATN Agency Limited and MFUSE Agency Limited). T&P is part of the WPP network and many of our employees are required to sign up to WPP’s Code of Conduct. In the unlikely event of a conflict between the two codes, the WPP code will take precedence.

T&P operates in many markets and countries throughout the world. In all instances, we respect national laws and any other laws with an international reach, such as the UK Bribery Act, the US Foreign Corrupt Practices Act, and the UK Modern Slavery Act where relevant, and industry codes of conduct. We are committed to acting ethically in all aspects of our business and to maintaining the highest standards of honesty and integrity.

We, the officers and staff of all companies in our group, recognise our obligations to all who have a stake in our success including our staff, partners, clients and suppliers.

Information about our business shall be communicated clearly, and accurately in a non-discriminatory manner and in accordance with local regulations.

We select and promote our people on the basis of their qualifications and merit, without discrimination or concern for race, religion, national origin, colour, sex, sexual orientation, gender identity or expression, age or disability.

We believe that a workplace should be a safe and civilised place, and that all of our employees have a right to feel safe at all times whilst working for or representing us in the market place. We believe that employment must be freely chosen; we will not tolerate harassment, discrimination or offensive behaviour of any kind towards or by our staff, partners, clients or suppliers. This includes (without limitation) the persistent demeaning of individuals through words or actions, any aggressive, intimidating, threatening or violent words or behaviour, the use of sexist, homophobic or racist or otherwise offensive language, the display or distribution of offensive material, or the use or possession of weapons on T&P or client premises, or at T&P or client hosted events. We expect our people and those we work with (including our clients and suppliers) to behave ethically and with integrity, treating anyone they deal with in a professional and courteous manner.

We will not tolerate the use, possession or distribution of illegal drugs, or our people reporting for work under the influence of drugs or alcohol.

We will treat all information relating to T&P’s business, or to its clients, as confidential. In particular, “insider trading” is expressly prohibited and confidential information must not be used for personal gain.

We are committed to protecting consumer, client and employee data in accordance with national laws and industry codes.

We will not knowingly create work which contains statements, suggestions or images offensive to general public decency and will give appropriate consideration to the impact of our work on minority segments of the population, whether that minority be by race, religion, national origin, colour, sex, sexual orientation, gender identity or expression, age or disability.

We will not undertake work which is intended or designed to mislead, including in relation to social, environmental and human rights issues.

We will consider the potential for clients or work to damage T&P’s reputation prior to taking them on. This includes reputational damage from association with clients that participate in activities that contribute to the abuse of human rights.

We will consider the potential for our clients and suppliers to damage T&P’s reputation prior to taking them on. This includes reputational damage from association with suppliers that participate in activities that contribute to the abuse of human rights.

We will not give, offer or accept bribes, whether in cash or otherwise, to or from any third party, including but not restricted to government officials, clients and brokers or their representatives. We will collectively ensure that all staff understand this policy through training, communication and by example.

We will not offer any items of personal inducement to secure business. This is not intended to prohibit appropriate entertainment or the making of occasional gifts of minor value unless the client has a policy which restricts this.

We will not accept for our personal benefit goods or services of more than nominal value from suppliers, potential suppliers or other third parties.

We will not have any personal or family conflicts of interest within our businesses or with our suppliers or other third parties with whom we do business.

No corporate contributions of any kind, including the provision of services or materials for less than the market value, may be made to politicians, political parties or action committees, without the prior written approval of the T&P Board of Directors.

We will continue to strive to make a positive contribution to society and the environment by: maintaining high standards of marketing ethics; respecting human rights in our business supply chain and through our client work; respecting the environment; supporting community organisations; supporting employee development; and managing significant corporate responsibility risks in our supply chain. Our Sustainability Policy and our Human Rights Policy Statement provides more detail about our commitments in these areas.

Actual or potential conflicts with this Code should be reported promptly to T&P’s Global CFO.

Complaint procedure

We want to encourage a culture of integrity and transparency and we want our people to do the right thing automatically. Part of this culture is making sure that anyone we work with (including our colleagues, clients and suppliers) are encouraged to speak up about any concerns that they have about behaviour which may be a breach of this Code of Business Conduct. To allow anyone we work with to raise a concern in complete confidence, we operate our &Action account. Please send any concerns in the first instance to AndAction@theandpartnership.com. Any concerns you raise this way will be treated completely confidentially and you have the option of remaining anonymous if you wish (please confirm when you raise the concern).

Alternatively, concerns can be raised to our Global Head of People (alex.mowle@theandpartnership.com), General Counsel (gillie.abbotts-jones@theandpartnership.com) or Global CFO (david.graham@theandpartnership.com). Again, with concerns raised in this way you have the option of remaining anonymous if you wish (please confirm when you raise the concern).

If you feel uncomfortable with reporting concerns in this way, you also have the option of raising any concerns via our group company WPP Plc’s confidential Speak Up helpline: (please see here for full details, including contact details: RTS_UK-NI.pdf (wpp.com).

We do not tolerate any retaliatory behaviour against individuals reporting concerns. We are committed to providing a safe and confidential way for people with genuine concerns to raise them, and to do so without fear of reprisals. If you raise a concern, please be aware that in some cases, for example for legal reasons, we may not be able to provide you with a report of how any subsequent investigation is concluded. Where we can provide a response, we will aim to do so within five working days of the conclusion of the investigation.

If the result of the investigation indicates that corrective action is called for, such action may include disciplinary measures up to and including termination of the employment of the offender, or if the offender is a client or a partner then we may seek to end that client relationship.

Annual compliance

All staff are required to complete the mandatory WPP training modules, details are available from the People Team. The People Team are responsible for ensuring that their team members have completed the training, and that their businesses are being operated on a day to day basis in compliance with the Code of Business Conduct.

Human Rights Policy Statement

Respect for human rights and compliance with relevant law are fundamental principles for T&P. In our business activities we aim to prevent, identify and address negative impacts on human rights and we look for opportunities to positively promote and support human rights, including children’s rights.

T&P is part of the leading global agency network, WPP Plc. We are guided by WPP’s approach to human rights respect and compliance, including compliance with applicable international standards and principles.

This policy statement explains how human rights are relevant to our business and the steps we take to protect human rights. It applies to all of our subsidiaries and should be read in conjunction with the T&P Code of Business Conduct and Sustainability Policy.

What Human Rights issues means to T&P?

The main ways that human rights are relevant to T&P are:

Employees

We respect the human rights of all employees, including permanent, temporary and contract workers. We select and promote our people on the basis of their qualifications and merit, encouraging diversity. We expect all employees to be treated without discrimination or concern for factors such as race, religion, national origin, colour, sex, sexual orientation, gender identity or expression, age or disability. We seek to provide safe workplaces. We recognise the rights of our employees to freedom of association and collective bargaining. We will not tolerate harassment or any form of forced compulsory or child labour.

Suppliers

We expect our suppliers to respect the human rights of their own employees and suppliers and to meet human rights standards that are consistent with T&P’s.

Client work

T&P will not undertake work designed to mislead on human rights issues. Where relevant, we will work with our clients on human rights issues and comply with client policies in relation to human rights and marketing.

Work for human rights organisations

Communications campaigns can be used to raise awareness of human rights issues and to encourage action to protect human rights. Our agencies provide creative services to organisations involved in protecting and promoting human rights, often on a pro bono basis (for little or no fee). T&P supports and encourages this involvement.

Our policy

To embed our commitment to protect and promote human rights, T&P will:

Comply with all relevant laws and support international human rights standards.
Reflect our commitment to human rights in our policies and procedures.
Take steps to identify, prevent or address human rights impacts. This includes integrating human rights into our risk management processes.
Provide training for our employees on human rights.
Operate a grievance mechanism to enable employees and suppliers to report human rights concerns.
Regularly review and update our approach to human rights.
Take steps to support and promote human rights, including through our pro bono work.

Responsibilities

Our Global Head of People has responsibility for overseeing our approach to human rights.

It is the role of the company to communicate this policy to all T&P businesses, to provide support and guidance for T&P business leaders and employees on human rights and to integrate human rights considerations into all policies and procedures where relevant.

Reporting a concern

T&P employees can report any human rights concerns via our Right to Speak facility, which is operated via our parent company, WPP.

Suppliers and other stakeholders can report any human rights concerns in relation to T&P and its companies via a WPP independently managed phone line. Details are provided on WPP’s website.

Sustainability Policy

Managing social, ethical and environmental risks helps us achieve our business goals and enhances our reputation with clients, employees, regulators and investors. Serving the sustainability communications needs of our clients is a growing business opportunity for T&P and we aim to be a centre of excellence for environmental and social communication.

We focus our efforts on the issues that are most important to T&P. These are:

The social and environmental impact of our work for clients.
Risks to T&P’s reputation from undertaking controversial client work.
Marketing ethics and compliance with marketing standards.
Privacy and data protection.
Protecting and promoting human rights in relation to our employees and suppliers; and the impact of our work for clients.
Employment, including diversity and equal opportunities, business ethics, employee development, remuneration, communication and health and safety.
Social investment, including pro bono work, donations to charity and employee volunteering.
Climate change, including the emissions from energy used in our offices and during business travel.
Sustainability in our supply chain.

How we manage sustainability

The Risk Committee is responsible for sustainability, including carrying out an annual assessment of sustainability risks and performance and setting action points for T&P.

T&P Sustainability policy

We believe our business can make a positive contribution to society and the environment by managing our activities with care and by working with responsible organisations that promote social and environmental causes.

Social investment

T&P companies are encouraged to:

Undertake pro bono work for not-for-profit organisations involved in tackling social and environmental issues.
Make appropriate financial and other donations to social and environmental organisations.

Managing relationships

In all our relationships we will be open, honest and transparent and will not pay or receive bribes or inducements of any kind.

Employee development

We select and promote our people on the basis of qualifications and merit, without discrimination or concern for race, religion, national origin, colour, sex, sexual orientation, gender identity or expression, age or disability.

We support training and career development for our people.

We provide a safe and civilised workplace free from sexual harassment or offensive behaviour.

Marketing ethics

We will comply with applicable regulations and self-regulatory codes of practice in the countries in which we operate.

We will not undertake work designed to mislead in any respect, including social, environmental and human rights issues.

Environment

We will respect the environment by minimising our impact from:

Energy use;
Transport;
Consumption of paper and other resources;
Water use;
Managing any significant Sustainability risks in our supply chains.

Human rights

In our business activities we aim to prevent, identify and address negative impacts on human rights, and we look for opportunities to positively promote and support human rights, including children’s rights. We comply with our Human Rights Policy Statement which reflects international standards and principles.

We support the right of our people and their families to basic human rights including the right to organise, the right to fair conditions of work, freedom of opinion and expression and freedom from forced labour and child labour.

We expect our suppliers to adopt human rights standards consistent with our own.

Charitable donations

Individual business lines are responsible for their own charitable policies, as projects or organisations to which donations are made will vary according to local circumstances and staff preferences but these donations should be discussed with Business Leads in advance.

Environmental strategy

Reducing our impact on the environment is a priority. We aim to make T&P a low-carbon company. We are also focusing on reducing waste and managing water use in regions of water scarcity.

T&P recognises that the pursuit of economic growth and a healthy environment are inextricably linked. Sound business management must take into account the effects of its business on the environment. T&P supports practical measures and policies, which will help to protect and improve the environment. It endeavours to adopt good environmental practice in respect of premises, equipment, and consumption of resources.

Climate change

Our climate strategy focuses on three areas:

Improving energy efficiency in our buildings and IT.
Reducing non-essential flights.
Purchasing renewable electricity where available.

We offset emissions from flights by investing in renewable energy projects.

Waste

Key commitments include:

Paper

Use sustainable-sourced paper by 2024. This includes paper with recycled content and paper certified to recognised sustainability standards such as FSC and PEFC.
Set printers to double sided as default.

Electronic waste (e.g. IT and mobile phones)

Our policy is that obsolete IT equipment should be refurbished and sold for reuse, or if this is not possible, be broken down for recycling. Disposal is a last resort and must be done in compliance with local environmental regulations and data security best practice (which also ensure that any corporate or confidential data is cleansed from the equipment).

Office consumables (e.g. paper, card, cans, plastic bottles, toner cartridges)

To make it easier for our operating companies to recycle their waste we have identified preferred suppliers of recycling services for paper, standard office consumables and mobile phones in all major markets.

Water Use

We aim to use water carefully and integrate water conservation into our property acquisition and refurbishment process particularly in water stressed regions.

The&Partnership Group Ltd. Privacy Policy

Overview – the key information you should be aware of

(A) Who we are: We are The & Partners Group Limited (a company registered in England and Wales (company number 8721455), whose registered office is at 7 Rathbone Street, London W1T 1LY, United Kingdom) – also referred to in this policy as ‘we’, ‘us’ and ‘T&P’. Any references in this policy to ‘we’, ‘us’ and ‘T&P’ include references to all of the agencies in our group, including M/SIX Communications Limited, Halpern Limited, Muster Agency Limited, ATN Agency Limited and MFUSE Agency Limited.

References in this policy to “our website” are to the website at www.theandpartnership.com and any websites of the agencies in our group listed above. If you wish to contact us about anything in this privacy policy please email us at safeandsound@theandpartnership.com.

(B) Our values and what this policy is for: We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your rights in relation to your information which you can find in section 6

In line with these values, this privacy policy tells you what to expect when we collect and use personal information about you. We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you.

We are always looking to improve the information we provide to our customers and contacts so if you have any feedback on this privacy policy, please let us know using our contact details in section 12.

Visitors to our website;
Business contacts ; and

Depending on our relationship, we will collect and use your information in different ways. Please click on the links above to find out the information that we collect about you and how we use this information.

(D) What this policy contains: This privacy policy describes the following important topics relating to your information (you can click on the links to find out more):

How we obtain your personal information
Collection of your personal information and how we use it
Legal basis for use of your personal information
How and why we share your personal information with others
How long we store your personal information
Your rights
Marketing
Where we may transfer your personal information
Risks and how we keep your personal information secure
Links to other websites
Changes to our privacy policy
Further questions and how to make a complaint

(E) Your rights to object: You have various rights in respect of our use of your personal information as set out in section 6.Two of the fundamental rights to be aware of are that you may:

ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using your personal information for this purpose;
ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person’s, legitimate interest.

You can find out more information in section 6

(F) What you need to do and your confirmation to us: Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.

The detail – the key information you should be aware of

1. How we obtain your personal information

1.1 You may provide us with your personal information voluntarily. However, we may also receive information about you from third parties such as our suppliers and public websites, which we refer to as “third party sources” or “suppliers” throughout this policy.

1.2 You may give us personal data about yourself in the course of interactions with our staff (for instance if you give them your business card), when you fill in a form on our website or when you contact us by phone, e-mail or other means. If you contact us, we may keep a record of that correspondence. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to such surveys.

2. Collection of your personal information and how we use it

Please go to the section or sections below that best describes our relationship with you to find out the information that we collect about you and how we use this information. We refer to this as “personal information” throughout this policy.

2.1 Visitors to our website

(a) What personal information we collect about you

We, or third parties on our behalf, collect and use technical information created and recorded automatically when you visit our website. This includes: The Internet Protocol (IP) address used to connect your computer to the internet address; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform. We use this personal information to administer our website, to measure the efficiency of our systems and to undertake an analysis of the locations from which people access our webpages;

(b) How we use your personal information

We will collect, use and store the personal information listed above for the following reasons:

(i) to allow you to access and use our website;

(ii) for improvement and maintenance of our website and to provide technical support for our website; and

(iii) to evaluate your visit to the website through the use of cookies (click here for a link to our Cookie Policy). Please see sections 2.3 and 2.4 for more details about how we use your personal information.

2.2 Business contacts

(a) We, or third parties on our behalf, collect and use the following information about you:

(i) your name;

(ii) your business postal address;

(iii) your business email address;

(iv) your telephone number;

(v) information about your preferences; and

(vi) any information provided by you when you correspond with us.

(b) How we use your personal information

We will collect, use and store the personal information listed above for the purposes of contacting you in the normal course of doing business with you and/or your employer, dealing with any enquiries from you and also, for business development and marketing purposes, to contact you (including by email or post) with information about our services which you request or which we feel will be of interest to you (including newsletters).

Please see sections 2.3 and 2.4 for more details about how we use your personal information.

(c) Source of personal information. We may receive some of your personal information from third parties, such as marketing agencies and third-party email marketing platforms.

2.3 Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:

(a) to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;

(b) for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;

(c) to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and

(d) to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.

2.4 Further processing

We will not use your personal information in any way that is incompatible with the purposes set out in this section 2. Please contact us using the details in section 12 if you want further information on the analysis we will undertake to establish if a new use of your personal information is compatible with these purposes.

3. Legal basis for use of your personal information

3.1 We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:

(a) our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the terms of use of our website which you accept by browsing our website); or

(b) our use of your personal information is necessary for complying with our legal obligations (for example, if you contact us requesting access to personal data we hold about you); or

(c) where use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:

(i) run, grow and develop our business;

(ii) carry out marketing, market research and business development;

(iii) provide services to our customers, make and receive payment and provide customer services;

(iv) place, track and ensure fulfilment of orders with our suppliers; and

(v) carry out internal group administrative purposes.

3.2 If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details at section 12

4. How and why we share your personal information with others

4.1 We will share your personal information with our group companies where it is in our legitimate interests to do so for internal administrative and business development purposes (for example, ensuring consistent and coherent delivery of our services to our customers, corporate strategy, compliance, auditing and monitoring, research and development, cross-selling within our group and quality assurance).

4.2 We will share your personal information with the following third parties or categories of third parties:

(a) service providers in relation to events we invite you to attend;

(b) our other service providers and sub-contractors, including but not limited to production companies, legal and other professional advisors, CRM platform providers, payment processors, insurers, warehouse, storage and logistics providers and cloud service providers.

(c) Salesforce UK Limited. Salesforce is one of our service providers. If you wish to download a White Paper from our website you will first be asked to enter some personal data. This personal data will be shared with Salesforce and will be dealt with in accordance with their Privacy Policy. Salesforce’s privacy policy can be found at Salesforce’s Privacy Information – Salesforce.com.

If you wish to opt out from any of the above data sharing you can email us at the following address: Email.optout@theandpartnership.com

4.3 Any third parties with whom we share your personal information are limited (by law) in their ability to use your personal information for any purpose other than to provide services for us. We will always ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy policy and applicable laws.

4.4 We will also disclose your personal information to third parties:

(a) where it is in our legitimate interests to do so to run, grow and develop our business:

(i) if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;

(ii) if substantially all of our or any of our affiliates’ assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;

(b) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;

(c) in order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or

(d) to protect the rights, property, or safety of T&P, our staff, our customers or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection and credit risk reduction.

4.5 We may also disclose and use anonymised, aggregated reporting and statistics about users of our website or our goods and services for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.

4.6 Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us, and we will stop doing so.

5. How long we store your personal information

5.1 We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time we retain personal information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights. If you have any queries please contact us (see section 12 below).

5.2 Where you fill out our online application form for jobs/placements, we retain the personal information provided for 2 years.

6. Your rights

6.1 You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at safeandsound@theandpartnership.com at any time. You have the following rights:

(a) Right of access. You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation whether your personal information is being used by us; details about how and why it is being used; and details of what safeguards are in place if we transfer your information outside of the European Economic Area (“EEA“).

(b) Right to update your information. You have a right to request an update to any of your personal information which is out of date or incorrect.

(c) Right to request deletion of your information. You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 12.

We will pass your request on to other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details in section 12.

(d) Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 12.

We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contract details in section 12.

(e) Right to stop marketing: You have a right to ask us to stop using your personal information for direct-marketing purposes (see section 7 below). If you exercise this right, we will stop using your personal information for this purpose.

(f) Right to data portability: You could have a right to ask us to provide your personal information to a third-party provider of services. This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.

(g) Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.

6.2 We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period allowed by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

6.3 If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

7. Marketing

7.1 We may collect and use your personal information for undertaking marketing by email telephone and post.

7.2 We may send you certain marketing communications (including electronic marketing communications to existing customers) if it is in our legitimate interests to do so for marketing and business development purposes.

7.3 However, we will always obtain your consent to direct marketing communications where we are required to do so by law (for instance if we want to send email marketing to consumers at their personal email addresses).

7.4 If you wish to stop receiving marketing communications, you can contact us by email at Email.optout@theandpartnership.com

8. Where we may transfer your personal information

- Your personal information may be used, stored and/or accessed by staff operating outside the EEA working for us, other members of our group, third party partners or suppliers. Further details on to whom your personal information may be disclosed are set out in section 4.
- If we provide any personal information about you to any such non-EEA members of our group or third parties, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this privacy policy. These measures may include the following permitted in Articles 45 and 46 of the General Data Protection Regulation:
  - in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome); or
  - in the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.

8.3 Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us by email at safeandsound@theandpartnership.com at any time.

9. Risks and how we keep your personal information secure

9.1 The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public information that you would prefer to keep private.

9.2 For this reason, we are committed to protecting your personal information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures. Organisational measures include, implementing internal policies and staff training and ensuring confidentiality obligations are imposed on our employees and third parties. Technical measures include requiring passwords for access to our systems, the use of encryption and anti-virus software and logically separating data.

9.3 In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted online and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.

10. Links to other websites

Our website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. This privacy policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third-party websites or third-party terms and conditions or policies.

11. Changes to our privacy policy

We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you in other ways (such as a prominent announcement on our website). Please check back frequently to see any updates or changes to our privacy policy.

12. Further questions and how to make a complaint

12.1 If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact our Data Protection Team at safeandsound@theandpartnership.com or at 17 Gresse St, London, W1T 1QL, 020 70799800. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information. Alternatively, if you wish to report a suspected data breach, please email us at data.breach@theandpartnership.com.

12.2 In accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the Information Commissioner’s Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.

The practices described in this privacy policy statement are current as of September 2021.

The&Partnership Group Ltd. Cookies Policy

Who we are:

We are The & Partners Group Limited (a company registered in England and
Wales (company number 8721455), whose registered office is at The Charlotte Building, 17 Gresse Street, London, W1T 1QL, United Kingdom) – also referred to in this policy as ‘we’, ‘us’ and ‘T&P’.

References in this policy to “our website” are to the website at www.theandpartnershiplondon.com. If you wish to contact us about anything in this privacy policy, please email us at safeandsound@theandpartnership.com.

Our values and what this policy is for:

We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your rights in relation to your information which you can find in section 6.

Who this policy applies to:

This policy applies to: Visitors to our website (Section 2.1); Business contacts (Section 2.2); and Applicants for jobs/placements (Section 2.3);

What this policy contains:

This privacy policy describes the following important topics relating to your information:

How we obtain your personal information
Collection of your personal information and how we use it
Legal basis for use of your personal information
How and why we share your personal information with others
How long we store your personal information
Your rights
Marketing
Where we may transfer your personal information
Risks and how we keep your personal information secure
Links to other websites
Changes to our privacy policy
Further questions and how to make a complaint

Your rights to object:

You have various rights in respect of our use of your personal information as set out in section 6. Two of the fundamental rights to be aware of are that you may:

ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using your personal information for this purpose;
ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person’s, legitimate interest.

You can find out more information in Section 6.

What you need to do and your confirmation:

Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.

The detail – the key information you should be aware of:

1.How we obtain your personal information

You may provide us with your personal information voluntarily. However, we may also receive information about you from third parties such as our suppliers and public websites, which we refer to as “third party sources” or “suppliers” throughout this policy.
You may give us personal data about yourself in the course of interactions with our staff (for instance if you give them your business card), when you fill in a form on our website or when you contact us by phone, e-mail or other means. If you contact us, we may keep a record of that correspondence. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to such surveys.

2.Collection of your personal information and how we use it

2.1 Visitors to our website

What personal information we collect about you
- We, or third parties on our behalf, collect and use technical information created and recorded automatically when you visit our website. This includes: The Internet Protocol (IP) address used to connect your computer to the internet address; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform. We use this personal information to administer our website, to measure the efficiency of our systems and to undertake an analysis of the locations from which people access our webpages;
How we use your personal informationWe will collect, use and store the personal information listed above for the following reasons:
- to allow you to access and use our website;
- for improvement and maintenance of our website and to provide technical support for our website; and
- to evaluate your visit to the website through the use of cookies (see below for our cookie policy). Please see sections 2.4 and section 3 for more details about how we use your personal information.
A word about cookies
- Some pages on our website use cookies, which are small files placed on your internet browser when you visit our website. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.
- Where we use cookies on our website, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our website or to use all the functionality provided through our website.
The only cookies that are used on our websites are Google Analytics – Our Cookie policy is detailed below.
- Google: _ga_gid_gat
  - Google Analytics help us understand how our customers get to our website, the number of people that visit our site, and how they navigate their way around the site once they’re there. We can use this information to improve our visitors’ user experience. Google’s Privacy policy is available at policies.google.com/privacy?hl=en

_icl_current_language

We use _icl_current_language to remember your region preference, when you select a location from either the region selector pop-up displayed when you first visit our website, or from the main navigation drop-down menu.

-vuid (.vmeo.com)

-vuid is placed on your computer when using our website, enabling video that we embed from Vimeo to be played. Vimeo’s embeddable video player uses first-party cookies that we consider essential to the video player experience. By using Vimeo’s websites, apps, or video player, you consent to the placement and use of cookies and similar technologies on your device.

-player (.vmeo.com)

-player (.vmeo.com) The embedded Vimeo player uses these cookies to confirm if certain features or preferences have been selected by the user. To find about more about how each cookie is used see Vimeo’s cookie list. More information can be found on Vimeo’s privacy policy.

John

John saves your preference for cookie usage on our website, when you click ‘continue’ on our cookies banner. By pressing ‘continue’ you agree with our Cookies Policy, and we will remember this for 30 days.

Doe

Doe saves your region preference for viewing our website, when you select this from the region navigation banner. By selecting the ‘close’ button you choose to remain on the Global website. We will remember this information for 1 day.

2.2 Business contacts

We, or third parties on our behalf, collect and use the following information about you:
- your name;
- your business postal address;
- your business email address;
- your telephone number;
- information about your preferences; and
- any information provided by you when you correspond with us.

How we use your personal information
- We will collect, use and store the personal information listed above for the purposes of contacting you and/or arranging travel/other services for you in the normal course of doing business with you and/or your employer, dealing with any enquiries from you and also, for business development and marketing purposes, to contact you (including by email or post) with information about our services which you request or which we feel will be of interest to you (including newsletters).

Please see sections 2.4 and section 3 for more details about how we use your personal information.

Source of personal information.
- We may receive some of your personal information from third parties, such as marketing agencies and third-party email marketing platforms.
Applicants for jobs/placements
- We, or third parties on our behalf, collect and use the following information about you when you submit an application via our website:
- Name, e-mail address and phone number
How we use your personal information:
- We will collect, use and store the personal information listed above for the purposes of assessing your application and contacting you.

2.3 Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:

to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;
for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;
to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.

2.4

Further processing

3.Legal basis for use of your personal information

We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:

our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the terms of use of our website which you accept by browsing our website); or
our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the terms of use of our website which you accept by browsing our website); or
where use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
- run, grow and develop our business;
- carry out marketing, market research and business development;
- provide services to our customers, make and receive payment and provide customer services;
- place, track and ensure fulfilment of orders with our suppliers; and
- carry out internal group administrative purposes.
If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details at section 12.

4.How and why we share your personal information with others

We will share your personal information with our group companies where it is in our legitimate interests to do so for internal administrative and business development purposes (for example, ensuring consistent and coherent delivery of our services to our customers, corporate strategy, compliance, auditing and monitoring, research and development, cross-selling within our group and quality assurance).

We will share your personal information with the following third parties or categories of third parties:
- service providers in relation to events we invite you to attend;
- our other service providers and sub-contractors, including but not limited to production companies, CRM platform providers, payment processors, insurers, warehouse, storage and logistics providers and cloud service providers.
Any third parties with whom we share your personal information are limited (by law) in their ability to use your personal information for any purpose other than to provide services for us. We will always ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy policy and applicable laws.
We will also disclose your personal information to third parties:
- where it is in our legitimate interests to do so to run, grow and develop our business:
  - if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
  - if substantially all of our or any of our affiliates’ assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;
- if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
- in order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
- to protect the rights, property, or safety of The&Partnership London, our staff, our customers or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection and credit risk reduction.

We may also disclose and use anonymised, aggregated reporting and statistics about users of our website or our goods and services for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.

Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us, and we will stop doing so.

5.How long we store your personal information

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time we retain personal information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

Where you fill out our online application form for jobs/placements, we retain the personal information provided for 2 years.

6.Your rights

You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at safeandsound@theandpartnership.com at any time. You have the following rights:

Right of access. You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation whether your personal information is being used by us; details about how and why it is being used; and details of what safeguards are in place if we transfer your information outside of the European Economic Area (“EEA“).
Right to update your information. You have a right to request an update to any of your personal information which is out of date or incorrect.
Right to request deletion of your information. . You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 12.We will pass your request on to other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details in section 12.
Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 12.We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contract details in section 12.
Right to stop marketing: You have a right to ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
Right to data portability: You could have a right to ask us to provide your personal information to a third-party provider of services. This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.
Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.

We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period allowed by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

7.Marketing

We may collect and use your personal information for undertaking marketing by email telephone and post.
We may send you certain marketing communications (including electronic marketing communications to existing customers) if it is in our legitimate interests to do so for marketing and business development purposes.
However, we will always obtain your consent to direct marketing communications where we are required to do so by law (for instance if we want to send email marketing to consumers at their personal email addresses).
If you wish to stop receiving marketing communications, you can contact us by email at safeandsound@theandpartnership.com.

8.Where we may transfer your personal information

Your personal information may be used, stored and/or accessed by staff operating outside the EEA working for us, other members of our group, third party partners or suppliers. Further details on to whom your personal information may be disclosed are set out in section 4.

If we provide any personal information about you to any such non-EEA members of our group or third parties, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this privacy policy. These measures may include the following permitted in Articles 45 and 46 of the General Data Protection Regulation:

in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome); or
in the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.

Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us by email at safeandsound@theandpartnership.com at any time.

9.Risks and how we keep your personal information secure

The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public information that you would prefer to keep private.

For this reason, we are committed to protecting your personal information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures. Organisational measures include, implementing internal policies and staff training and ensuring confidentiality obligations are imposed on our employees and third parties. Technical measures include requiring passwords for access to our systems, the use of encryption and anti-virus software and logically separating data.

In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted online and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.

10.Links to other websites

11.Changes to our privacy policy

12.Further questions and how to make a complaint

If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact safeandsound@theandpartnership.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.

In accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the Information Commissioner’s Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.

The practices described in this privacy policy statement are current as of May 2018

Tax Strategy

Updated August 2023

Introduction

This tax strategy applies to all taxes applicable to The&Partnership Group and the document will be reviewed annually, updated as appropriate and approved by the Chief Financial Officer (CFO), on behalf of the Board.

The CFO is accountable to the Risk Committee and the Board for the implementation of the tax strategy and the management of tax and related risk.

This tax strategy applies to all The&Partnership Group companies and to our dealings with our clients.

Governance and risk management

The Group is committed to the delivery of the tax strategy, and this will be owned by the Group’s CFO who is ultimately accountable for Tax, and who is also the Group’s Senior Accounting Officer.

The CFO has responsibility over The&Partnership’s approach to tax on day-to-day basis which includes the identification, prioritisation and monitoring of tax risk across the business, as well as the escalation of tax risk to the Board and the Risk Committee. The ongoing monitoring of tax accounting arrangements as part of annual SAO compliance provides part of this process.

Management of Tax Risk

As a large multi-national group with operations globally, the Group is exposed to a variety of tax risks. These can be grouped under the following headings:

Tax compliance and reporting risks, which cover risks associated with compliance failures such as submission of late or inaccurate returns, the failure to submit claims and elections on time or where finance or operational systems and processes are not sufficiently robust to support tax compliance and reporting requirements.
Transactional risks, which arise where transactions are carried out or actions are taken without appropriate consideration of the potential tax consequences or where advice taken is not correctly implemented.
Reputational risks, which looks beyond financial risks to the wider impact tax risk may have on our relationships with our stakeholders, including shareholders, clients, and the tax authorities.

The&Partnership works closely with WPP, our biggest shareholder, who have a team of tax professionals based predominantly in London and New York. Along with our external tax advisors, they provide advice on tax-related issues, undertake or assist with tax filings, manage relationships with tax authorities and assist with various forms of tax and financial reporting.

Where appropriate, we also engage with tax authorities to disclose and resolve issues, risks and uncertain tax positions. The subjective nature of many tax rules does however mean that it is often impossible to mitigate all known tax risk. Indeed, in certain situations, an element of tax risk may be maintained, where we believe our approach is consistent with the principles set out in our tax strategy and where the range of potential outcomes is in accordance with our risk parameters. Thus, at any given time, the Group may be exposed to some risk arising from its tax affairs, although we aim to manage and mitigate tax risk wherever possible.

Tax compliance and reporting

We are committed to meeting all our legal and regulatory requirements in paying the correct amount of tax and meeting our tax compliance obligations. For example, in the UK, as part of this commitment, we comply with the Senior Accounting Officer (‘SAO’) requirements and we undertake a review of our tax processes (for Corporation Tax, VAT and Employment Taxes) as part of this process.

We seek to apply diligent professional care and judgement in our tax compliance activities, and provide sufficient evidence to support all judgements made.

Relationships with Tax Authorities

The Group is committed to working collaboratively with tax authorities, through open and transparent dialogue to ensure it is compliant with all of its compliance and filing obligations. Wherever possible, we also seek to achieve early agreement on issues and certainty wherever possible.

Our approach to tax planning

We take a low-risk approach to tax planning, and tax decisions are aligned to business and commercial strategy. Like any other business expense however, we seek to create value for our partners. As such, we may respond to tax incentives and exemptions where appropriate and in a way that is consistent with tax authority and government policy.

As appropriate, we will seek external professional tax advice to ensure we apply these incentives and exemptions legitimately, and if appropriate, we seek advance clearances from the appropriate tax authority to ensure we minimise the risk of uncertainty.

Level of risk in relation to UK taxation that the Group is prepared to accept

Where tax law is unclear or subject to interpretation, we take external tax advice and any adopted tax position is at least probable to apply.

Transparency

We support initiatives to improve international transparency on taxation matters, including OECD measures on country-by-country reporting and automatic exchange of information.

We do not tolerate tax evasion, nor do we tolerate the facilitation of tax evasion by any person(s) acting on our behalf.

This Tax Strategy document

This document meets the requirement for The & Partnership to publish its Tax Strategy as required by paragraph 19 of Schedule 19 of the Finance Act 2016. It is effective and applies for our year ended 31 December 2023 financial year and was updated and approved by the Board in August 2023 and published in the same month.

Modern Slavery Act Statement

Modern Slavery Statement financial year ending 31 December 2022

Introduction

This is a statement made by The&Partners Group Limited and its subsidiaries (together being “T&P”) in relation to the Modern Slavery Act 2015 and describes our commitment and the steps we take to prevent modern slavery in our businesses and our supply chain. This statement covers the financial year ending 2022.

T&P is committed to ensuring compliance with all applicable laws, rules and regulations across our business and in our supply chains, acting ethically in all aspects of our business and maintaining the highest standards of honesty and integrity. This includes ensuring the prevention of modern slavery and other human rights breaches in our businesses and supply chains at all times.

About us

T&P is an independent agency holding company that brings together specialisms including creative and design, media planning and buying, content and digital engagement, PR and influencer marketing, live events and experiential, and data analytics and CRM. We are a cross-discipline group built for the current complex industry landscape.

WPP Plc (“WPP”) is a significant shareholder in T&P and our Board of Directors (comprising of directors from WPP and T&P) regularly monitors and reviews the steps that we are taking to ensure that there are no human rights breaches or modern slavery occurring in any of our businesses or supply chains. As a member of the WPP group we adhere to WPP’s Modern Slavery Statement which can be found at: Modern Slavery Act statement | Sustainability | WPP.

In 2022 (and for each financial year) we continued to review our business and supply chains, in particular in relation to sustainability. Our direct employees and officers are skilled professionals within the advertising, marketing and communications services sector and supply chains mainly include production companies, media agencies, software companies, I.T. and other office equipment, professional services, office cleaning and other office facilities services. As a consequence of this risk assessment we have concluded that we have a very low risk of any modern slavery in relation to our own business and/or our supply chains.

We do recognise that it is impossible to eliminate the risks in relation to third party suppliers (particularly production partners) and so in 2022 we have continued to focus our attention on identifying and minimising such risk in our supply chain (see ‘due diligence’ section below).

Our policies

Our Code of Business Conduct (Legal – The&Partnership (theandpartnership.com)) outlines how we are committed to acting ethically in all aspects of our business and to maintaining the highest standards of honesty and integrity. We specifically reference the Modern Slavery Act to highlight how seriously we take this issue. All of our people are required to uphold our Code of Business Conduct.

Our Code of Business Conduct – Supplier Version (Legal – The&Partnership (theandpartnership.com)) sets out our expectations of suppliers and is based on the above Code of Business Conduct that applies to all our companies and people. The supplier version includes requirements for labour practices (such as anti-harassment and discrimination, and health and safety), human rights (including no child, forced or bonded labour), and social impacts (such as anti-bribery and corruption) as well as other sustainability issues. The principles of the Code are embedded in our training courses.

Our Code of Business Conduct and Code of Business Conduct – Supplier Version is set within a wider ethical framework which includes our Human Rights Policy Statement, Anti-bribery and foreign corrupt practices Policy and our Sustainability Policy (Legal – The&Partnership (theandpartnership.com)). These policies outline our positive contribution to society and the environment underpinned by our responsibility to respect human rights.

Our Procurement and Contracting Policy, which is applicable to our employees (available upon request), outlines a clear procedure for responsible procurement. This includes the provision that, wherever possible, our companies should use centrally negotiated contracts with approved suppliers for commonly purchased goods and services.

Our People Team are responsible for recruitment and people management and work closely with our management team to ensure that all of our employees are treated with dignity and respect. We adhere to WPP’s commitment to pay no less than the voluntary living wage to our people and all on-site contractors such as cleaning, security and catering staff in the UK. This exceeds the UK’s statutory national living wage. The WPP group is a living wage employer accredited by the Living Wage Foundation.

Our employment policies address issues such as equal opportunities, protection of personal data, whistleblowing, harassment and bullying, health and safety in the workplace, holiday and sick pay. These policies are reviewed annually to ensure that we protect the rights and freedoms of all those working in our business. In 2022 we continued to monitor and review our policies, identifying any gaps, and ensured that appropriate policies were put in place to minimise any risks of modern slavery in our workforce or that of any of our suppliers.

Our General Counsel, external Legal Counsel, Chief Financial Officer and People Team led this review and have taken appropriate steps to monitor and ensure compliance with these policies within the workforce and in our supply chains throughout 2022. This includes by carrying out risk assessments of our workforce and supply chains and taking any required action as appropriate.

Effectiveness and Key Performance Indicators

We use a number of key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains, including KPIs regarding:

training our staff about modern slavery issues;
contacting our suppliers to seek information about their employee rights awareness training procedures or employee contracts;
regular auditing of our approach to managing the risk of modern slavery.

We started a review of our procurement processes and systems and in 2022, we carried out a wider programme review in anticipation of transformation, which incorporates our learnings from applying these KPIs.

Due diligence

We do not tolerate any form of modern slavery or human trafficking in any part of our business. As well as compliance with the codes described above, we require our suppliers to comply with all applicable laws, including modern slavery laws and to have suitable practices and procedures in place to ensure that human trafficking and slavery does not take place in their organisations or their supply chains. We enforce a strict code of compliance and do not tolerate slavery or human trafficking within our supply chains. We monitor our suppliers on an ongoing basis and will immediately seek to terminate our relationship with any suppliers who we believe may be involved in modern slavery or human trafficking.

We have identified all of our major suppliers and carried out a risk assessment in relation to these suppliers. This assessment concluded that these suppliers are very low risk from a modern slavery perspective. However, within the wider transformation of our procurement systems and processes, we have identified a need to modernise and standardise our due diligence and supplier onboarding processes across T&P to identify any issues and help us consistently select suppliers that meet our responsible sourcing standards and partner expectations.

Governance

We have established governance processes and policies to help us manage human rights risks, including modern slavery, consistently across T&P. In 2019 we set up a Risk and Compliance Committee to meet on a monthly basis to monitor compliance with all applicable laws across T&P, including in respect of our modern slavery obligations.

Following a review of our governance in 2021, in 2022 we recruited a General Counsel who oversees our approach to ethics and compliance and heads up our Risk and Compliance Committee. The Board, assisted by the Risk and Compliance Committee, has oversight and responsibility for our approach to risk management which is driven by our culture based upon the principles set out in our Code of Conduct. We also communicated our new governance policies to all of our staff.

Our next steps for 2023 include communicating our new governance policies to all of our specific workstreams in the business with a view to raising awareness and providing more training and re-assessing our procurement processes to ensure compliance with our policies.

This is in addition to the governance and compliance commitments made by WPP, as detailed in WPP’s Modern Slavery Act Statement (Modern Slavery Act statement | Sustainability | WPP).

Remediation

Our people can report concerns or suspected cases of misconduct confidentially (and, if they wish, anonymously) through our &Action account which is overseen by our People Team and General Counsel and is available via email. We publicise the facility in induction packs, on our intranet and external website, in offices, in our staff handbook and via our ethics training. Alternatively, if someone feels uncomfortable with reporting concerns in this way, they have the option to raise any concerns via WPP’s confidential speak up helpline: Right to Speak – insideWPP. We do not tolerate any retaliatory behaviour against individuals reporting concerns. We are committed to providing a safe and confidential way for people with genuine concerns to raise them, and to do so without fear of reprisals. To date we have received no Right to Speak reports about our business which relate to modern slavery.

Training

During 2022 all of our people (including freelancers working for more than four weeks) were required to complete WPP’s online ethics training, How We Behave, as part of their onboarding process. Topics covered include diversity, human rights, anti-bribery and corruption, conflicts of interest and avoiding misleading work. All of our policies are accessible by our people on our intranet. We are reviewing our approach to training with our newly appointed General Counsel and plan to roll out further training support during 2022-2023.

Conclusion

We are committed to ensuring that there is no modern slavery, human trafficking, or unlawful child labour in our supply chains or any part of our business. We will continue to review our policies and procedures, training and enforcement of our compliance commitments to ensure that the risk of slavery and human trafficking is carefully monitored and fully understood by all employees in our business and that it is not tolerated in our supply chains.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes T&P’s slavery and human trafficking statement for the financial year ending 31 December 2022. It was approved by T&P’s board of directors on 16 June 2022.

David Graham
Director and Global CFO
The&Partners Group Limited

Speak Up Policy

Our staff handbook and Code of Conduct set out our responsibilities to our people, partners and shareowners globally to act ethically and legally. We want to encourage a culture of integrity and transparency and we want our people to do the right thing automatically. Part of this culture is making sure that people have confidence to speak up and raise concerns if they experience or hear about behaviour which is at odds with the principles stated in our handbook or Code of Conduct (for a copy of our handbook or Code of Conduct please contact our Global HR Director).

To allow our people to raise a concern in complete confidence, we operate our &Action account. Send any concerns in the first instance to AndAction@theandpartnership.com. Any concerns that you send to this email address will be treated completely confidentially and you have the option of raising your concern anonymously if you wish (please confirm this when you raise the concern). Alternatively, if you feel uncomfortable with reporting concerns in this way, you have the option to raise any concerns via WPP’s confidential speak up helpline: Right to Speak – insideWPP.

We do not tolerate any retaliatory behaviour against individuals reporting concerns. We are committed to providing a safe and confidential way for people with genuine concerns to raise them, and to do so without fear of reprisals.
If you raise a concern, please be aware that in some cases, for example for legal reasons, we may not be able to provide you with a report of how any subsequent investigation is concluded. Where we can provide a response, we will aim to do so within five working days of the conclusion of the investigation.

Salesforce Privacy Policy

Introduction

This website www.theandpartnership.com, and the websites of any agencies within The&Partners Group Limited, including MSIX Communications Limited, Halpern Limited, Muster Agency Limited, ATN Agency Limited and MFUSE Agency Limited (“T&P”, “We”, “Us”) (such websites together and individually being referred to as a “Site”) are operated by T&P. This policy only applies to the sites where it is posted and applies to all those who have provided Personal Information (see below). We take the privacy of our website users and the security of their personal information very seriously and are committed to best practices. For our general privacy policy click – https://theandpartnership.com/cookies-policy. This contains details relating to the cookies that we use, at section 2.

The purpose of this privacy policy is to set out the principles governing our use of Personal Information that we may obtain about you. We ask you to read this privacy policy carefully. By engaging with us in the ways set out in this policy, you confirm that you have read and understood the entirety of this policy, as it applies to you.

We may change our privacy policy from time to time. Please check it occasionally to ensure that you are aware of the most recent version that will apply when you access this website.

You have various rights in respect of our use of your Personal Information as set out in section 11. If you have any questions on this policy please contact safeandsound@theandpartnership.com.

What information do we collect?

At times, we may request that you voluntarily supply us with personal information in order to download information from our website, or you may choose to provide us with your personal information by emailing us via the “Contact” section of this website (this is to be known as completing a “Contact Form”). Generally, this information is requested or provided when you want us to provide you with information.

We may gather the following information (“Personal Information”) about you including, but not limited to, the following:

Name
Company name
Email address
IP address (a unique identifier for your computer or other device)
Mobile device ID
Such other personal information provided by you when contacting us via the “Contact” sections of this website, email, phone or otherwise.

What Personal Information of yours are we processing?

Based on your answers on the Contact Form, we are processing the Personal Information defined above.

T&P holds your Personal Information within a piece of client relationship management (“CRM”) software (with additional security measures taken to ensure that your Personal Information is secure).

Collection of your Personal Information and how we use it

Once you have entered your Personal Information into the Contact Form, this information is then held within the CRM system.

We may then use your Personal Information to send you information which we think you may find useful about our business (including but not limited to business news, recent white papers and invitations to one of our client events).

Legal basis for use of your Personal Information

We consider that the legal bases for using your Personal Information as set out in this Policy are as follows:

Consent. We will use your Personal Information to provide you with materials and information you have requested and to respond to specific queries you may raise regarding T&P and its various operating companies and brands. We will also use your Personal Information to send you information and materials that may be of interest to you, such as newsletters, whitepapers, news bulletins, and other business information.

We gave you information on the pages into which you entered your Personal Information in which we made the purpose of our collection and use of the Personal Information clear to you, as well as the fact that provision by you of the Personal Information was entirely voluntary. However, you may withdraw your consent at any time by contacting us at email.optout@theandpartnership.com or by clicking on the unsubscribe option at the bottom of any emails we send you.

Legitimate interests. We are also processing your Personal Information in order to achieve a number of legitimate interests which are set out in our general privacy policy. Please click https://theandpartnership.com/cookies-policy/ for more details.

Please note that if we rely on our (or another person’s) legitimate interests for using your Personal Information, we will first undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of your Personal Information. You can ask us for information on this balancing test by using the contact details at the end of this Policy.

Additional use of your Personal Information (Legitimate Interests)

We may also collect, use and store your Personal Information for the following additional reasons:

(a) to deal with any enquiries or issues you have about how we collect, store and use your Personal Information, or any requests made by you for a copy of the Personal Information we hold about you;

(b) internal reporting and administration purposes. We may process your Personal Information for these purposes where it is in our legitimate interests to do so;

Before using your Personal Information for any purposes which fall outside those set out in this Policy, we will undertake an analysis to establish if our new use of your Personal Information is compatible with the purposes set out in this section. Please contact us using the contact details at the end of this Policy if you want further information on the analysis we will undertake.

Sharing your Personal Information

Unless we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, any lawful request from government or law enforcement officials, to defend a legal action against us or prevent unlawful activity, we will not share your Personal Information with other third parties engaged with T&P.

How long we store your Personal Information

We keep your Personal Information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain Personal Information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights. If you would like further information on how long we retain your Personal Information then please contact us at safeandsound@theandpartnership.com.

Where we may transfer your Personal Information

We are a global company and therefore we may transfer your personal information to countries around the world including the US and other countries outside Europe. We will, where the country to which your data is transferred has not been found to provide an adequate level of protection, put in place appropriate safeguards (we use standard contractual clauses) to ensure your information is protected.

We also use a number of suppliers and service providers in connection with the operation of our business who may have access to the personal information that we process, e.g. IT suppliers when providing us with software support, or cloud services, or a company which we use for a marketing campaign may process your contact information on our behalf. In all cases, your personal information is handled and protected in accordance with data protection law.

Risks and how we keep your Personal Information secure

The main risk of our processing of your Personal Information is if it is lost, stolen or misused. This could lead to your Personal Information being in the hands of someone else who may use it fraudulently or make public information that you would prefer to keep private.

For this reason, T&P is committed to protecting your Personal Information from loss, theft and misuse. We have taken a number of precautions to safeguard the confidentiality of your Personal Information, including through use of appropriate organisational and technical measures (such as password protecting your Personal Information and limiting access appropriately).

Your Rights

In addition to your right to withdraw consent at any time as explained above, you also have the following rights in respect of our collection and use of your Personal Information:

The right of access to the personal data we hold about you. You have a right of access to any Personal Information we hold about you. You can ask us for a copy of your Personal Information; confirmation as to whether your Personal Information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the United Kingdom or the European Economic Area (“EEA”).

The right to rectification if any Personal Information we hold about you is inaccurate or incomplete. You have a right to request an update to any of your Personal Information which is out of date or incorrect.

Right to delete your information. You have a right to ask us to delete any Personal Information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details at the end of this Policy.

The right to restrict (i.e. prevent) the processing of your Personal Information. You have a right to ask us to restrict the way that we process your Personal Information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details at the end of this Policy.

Right to data portability: You have a right to ask us to provide your Personal Information to a third-party provider of services.

This right only applies where we use your Personal Information on the basis of your consent or performance of a contract; and where our use of your Personal Information is carried out by automated means.

Right to object. You have a right to ask us to consider any valid objections which you have to our use of your Personal Information where we process your Personal Information on the basis of our or another person’s legitimate interest.

We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain Personal Information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

Contacting Us

If you have any questions about this Policy and how it affects you, please contact us by email at safeandsound@theandpartnership.com.

Alternatively, if you are concerned that there may have been a data breach of any kind, please contact us by email at data.breach@theandpartnership.com.

Policy review

This Policy was last reviewed in August 2021. The content of the Policy may be reviewed and changed without prior notice. Any changes we make to our Policy in the future will be posted online and, if any significant changes are made to the Policy, this will be communicated to you.

Code of Business Conduct for Suppliers

T&P and all of the agencies within our group operate in many markets and countries throughout the world. In all instances, we respect national laws and any other laws with an international reach, such as the UK Bribery Act, the US Foreign Corrupt Practices Act and the UK Modern Slavery Act, where relevant, and industry codes of conduct. We are committed to acting ethically in all aspects of our business and to maintaining the highest standards of honesty and integrity.

We expect and require all our business partners, including suppliers, to have the same commitment to ethical behaviour and therefore ask you to confirm your agreement with our Code of Business Conduct (in the first column) as amended where necessary for you as our suppliers (in the second column).

We expect all our suppliers to use appropriate systems to facilitate and monitor compliance with these standards and adherence to local and applicable international laws. We expect our suppliers to demonstrate their commitment to the principles of this code and to have an on-going process of risk management to identify the environmental, health and safety, and labour practices and ethics risks associated with their operations.

Suppliers should encourage staff to report concerns without fear of threat or reprisal. Suppliers should take appropriate action as required.

Suppliers should put in place equivalent standards to this code for their own supply chain.

T&P’s Code

What T&P expects from its suppliers

We, the officers and staff of all companies in the T&P group (the “Group”), recognise our obligations to all who have a stake in our success including partners, clients, staff and suppliers.

You confirm that you recognise our obligation and will not act detrimentally to these obligations.

Information about our business shall be communicated clearly and accurately in a non-discriminatory manner and in accordance with local regulations.

You confirm that you will treat information about the Group as described.

You confirm that you have equivalent policies in your organisation.

We believe that a workplace should be a safe and civilised place, and that all of our employees have a right to feel safe at all times whilst working for or representing us in the marketplace. We believe that employment must be freely chosen; we will not tolerate sexual harassment, discrimination or offensive behaviour of any kind towards or by our staff, partners, clients or suppliers. This includes (without limitation) the persistent demeaning of individuals through words or actions, any aggressive, intimidating, threatening or violent words or behaviour, the use of sexist, homophobic or racist or otherwise offensive language, the display or distribution of offensive material, or the use or possession of weapons on T&P or client premises, or at T&P or client hosted events. We expect our people and those we work with (including our clients and suppliers) to behave ethically and with integrity, treating anyone they deal with in a professional and courteous manner.

You confirm that you have equivalent policies in your organisation and for your supply chain, and that you will respect our workplace and people as described. In particular (but without limitation):

• Employment must be freely chosen; forced or bonded labour or any other form of modern slavery must not be used. Workers rights in respect of freedom of association and collective bargaining must be supported;

• Workers must not be forced to submit passports or government issued identities as a condition of employment;

• Child labour is not to be used;

• Compensation paid to workers must be fair and comply with all applicable wage laws, with recruitment fees being paid for by the employer;

• Work weeks and hours must be reasonable and are not to exceed the maximum set by local law and overtime must be voluntary;

• There is to be no inhumane, aggressive, intimidating, threatening or violent or offensive behaviour, treatment or language towards any

workers including sexual harassment, sexual abuse, physical or mental punishment or coercion or verbal abuse;

• T&P expects its suppliers to create and

foster safe and hygienic working conditions for all workers;

• Worker exposure to physical hazards must be eliminated wherever possible, or, if not, must be controlled;

• Suppliers must have adequate and fair procedures and remedies available to its employees; and

• Systems must be in place to manage, track and report occupational injuries and illness.

We will not tolerate the use, possession or distribution of illegal drugs, or our people reporting for work under the influence of drugs or alcohol.

You confirm that you have equivalent policies in your organisation and that you will respect our workplace, your workers and our people as described.

We will treat all information relating to the Group’s business, or to its clients, as confidential. In particular, “insider trading” is expressly prohibited and confidential information must not be used for personal gain.

You confirm that you agree to our policy in respect of our information.

We are committed to protecting consumer, client and employee data in accordance with national laws and industry codes.

You confirm that you have equivalent commitments in your organisation that cover all information from and relating to our business and that of our partners in that business.

Wherever relevant, you confirm that you have equivalent standards for your work.

We will not undertake work which is intended or designed to mislead, including in relation to social, environmental and human rights issues.

Wherever relevant, you confirm that you have equivalent standards for your work.

We will consider the potential for clients or work to damage the Group’s reputation prior to taking them on. This includes reputational damage from association with clients that participate in activities that contribute to the abuse of human rights.

This relates only to members of the T&P Group.

We will consider the potential for our suppliers to damage the Group’s reputation prior to taking them on. This includes reputational damage from association with suppliers that participate in activities that contribute to the abuse of human rights.

We expect all of our suppliers to act professionally, lawfully and reasonably (including having mind to the best interests of the Group) whilst engaged by the Group and not to or cause to be done anything which might harm or damage the Group’s reputation.

This applies directly to you.

We will not accept for our personal benefit goods or services of more than nominal value from suppliers, potential suppliers or other third parties.

This applies directly to you.

We will not have any personal or family conflicts of interest within our businesses or with our suppliers or other third parties with whom we do business.

You should have equivalent policies in your organisation.

You should have your own policy regarding such contributions, together with appropriate authorisation procedures.

We will continue to strive to make a positive contribution to society and the environment by: maintaining high standards of marketing ethics; respecting human rights in our business, supply chain and through our client work; respecting the environment; supporting community organisations; supporting employee development; and managing significant sustainability risks in our supply chain. Our Sustainability Policy and Human Rights Policy Statement provide more detail about our commitments in these areas.

You should have equivalent policies in your organisation. In particular:

• Suppliers must comply with the requirements of the UK’s Modern Slavery Act;

• Suppliers must conduct business in a way which embraces sustainability and reduce environmental impact and must obtain all relevant environmental authorisations, including for waste and emissions;

• Suppliers must endeavour to prevent pollution by implementing conservation measures in their facilities and processes, by recycling, reusing and substituting materials.

Partner Results Statement

Please find our latest report of 5 year business performance available to view here.