Fundamental Media Limited (“Fundamental”, “us”, “we”, “our”) is a leading specialist in media consultancy and advisory services working with the financial industry providing media intelligence, planning and buying.  This statement is made in accordance with Section 54 of the Modern Slavery Act 2015 (“the Act”) and sets out the steps we have taken to understand and mitigate the potential human trafficking and slavery risks related to our business.  We are committed to conducting business ethically and responsibly and accordingly do not tolerate any form of human trafficking or slavery in any part of our business, including, by way of example, through any form of forced work (through mental or physical threat or abuse), any restriction of freedom placed on a worker by an employer or any activity where a worker is treated as a commodity or is bought or sold as property.

Our group of companies has offices in the UK, US, UAE and Hong Kong and work with clients from the asset management, securities services, investment and corporate banking, reinsurance and private banking sectors in markets across Europe, Asia, the Middle East and the Americas.  We provide analysis, planning and buying services to our clients; from print and digital media to sponsorship, social media, research, award, event, outdoor and mobile media. In doing so we appoint and buy services from third-party media suppliers (publishers and media owners) to supply their services to our clients. We only make such purchases and appointments with the pre-approval of our clients.  As a result, our supply chain comprises two types of supplier, (i) those who service Fundamental’s supply requirements across our offices including IT, research, facilities and professional services and (ii) those publishers and media owners who we appoint, with the pre-approval of our clients, to provide their services to Fundamental’s clients. These suppliers are diverse and spread throughout the geographies in which our clients advertise.

The recruitment of Fundamental’s employees is handled centrally within the UK, either directly or through reputable recruitment agencies who are fully advised of our requirements and expectations that they adhere strictly with the law.  References and right to work documentation for applicants are reviewed and followed up in accordance with Fundamental’s References policy. Most employees are recruited by Fundamental to permanent positions; with temporary positions, generally only being used as an interim measure. Fundamental strictly adheres to the standards required of it by employment law including relevant minimum age and wage legislation. Any issues or concerns relating to modern slavery are to be reported to Fundamental’s HR Officer who will investigate and act as necessary. Alternatively, employees are encouraged to report any concerns within the business via Fundamental’s whistleblowing policy. Accordingly, the risk of any human trafficking or slavery occurring within the Fundamental business is low.Fundamental works in accordance with its policy on Business Ethics which is communicated to all Fundamental employees and contained within the Employee Handbook.  This policy provides that Fundamental is committed to achieving the highest standards of quality, honesty, openness and accountability in all of its activities. Fundamental also believes that it has a moral obligation to take account of the impact of its activities on the local, national and global economy, the environment and the community in which it operates. As part of this Fundamental does not enter into business with any organisation found to support or be involved in any form of slavery.Our Business Ethics policy also sets out how we are to operate as a business partner and award contracts. Fundamental strives to work with reputable suppliers, who share the same values, approach and who meet our client’s objectives. Accordingly, Fundamental works to a standard procurement policy and we require that our employees comply with this at all times. This procurement policy will be kept under review in light of the requirements of the Act.Our standard terms require that our suppliers confirm they are compliant with the requirements of the Act (specifically prohibiting the use of any forced, bonded or trafficked labour), including making appropriate checks of any sub-contractors used (where permitted under the relevant agreement) and allowing us to audit their practices where appropriate.We will continue to review our policies and practices in this area. This statement has been approved by the Chief Executive Officer of Fundamental on behalf of the Board of Directors.



DATE: 17.05.2019