Modern Slavery Statement
MODERN SLAVERY STATEMENT 2019
INTRODUCTION TO OUR BUSINESS
Universal Music Publishing Limited, Universal Music Publishing International Limited and Universal Publishing Production Music Limited together with their various affiliated companies (collectively “Universal Music Publishing UK”) are part of the Universal Music Group and operate an array of businesses including in music publishing and production music.
OUR POLICIES ON MODERN SLAVERY AND HUMAN TRAFFICKING
Universal Music Publishing UK fully supports the aims of the Modern Slavery Act 2015 and is committed to carrying out its business in a fair and honest manner. We understand the importance of ethics in our business and we are constantly trying to improve our processes to ensure that we adhere to ethical business practices.
We are, and have been for many years, committed to human dignity and we respect the rights of individuals in every aspect of our work. Practices that degrade other people – discrimination, slavery, child labour and unfair and unsafe working conditions – have no place in our company, industry or society. We take steps to protect human rights in our business, including endeavouring to ensure we choose business partners who share our commitment to respecting human rights and doing business with integrity.
This statement reflects our commitment to acting ethically in our business relationships and the fact that we do not tolerate any form of slavery, human trafficking or child labour, including:
not using any form of forced, bonded, compulsory labour, slavery or human trafficking;
compliance with applicable national laws and regulations regarding working hours, minimum wages and benefits.
Due to the nature of our business, we assess that there is very low risk of slavery and human trafficking in our business and supply chains. We do not have specific key performance indicators in this area as we would expect any instance to be a breach of law and/or our company policies.
Our procurement process involves initiatives to identify and mitigate risk and we have in place systems to identify potential risk areas when engaging suppliers and we have due diligence and monitoring processes we adopt where risk is identified. We endeavour to ensure that contracts to be entered into with suppliers and contractors also contain provisions requiring both parties to comply with applicable laws and allow for us to terminate our contracts with any suppliers who do not comply. Notwithstanding the steps we take in this area, it is ultimately our suppliers’ duty to respect the applicable laws and ethics on human rights.
Our Code of Conduct identifies the risks of modern slavery in our business and sets out our policy in relation thereto. The Code of Conduct is made available to all employees and periodical online training is provided to ensure they are familiar with its principles.
MODERN SLAVERY ACT 2015
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st December 2019.
VP, Legal & Business Affairs
Universal Music Publishing UK