Modern Slavery Policy
Overview
This Modern Slavery Policy sets out the policy of Simplicity Marketing Limited (UK), together with its affiliated companies in the United Kingdom from time to time (including without limitation Flash Topco Limited (UK), Flash Bidco Limited (UK) , and Innovid EU Limited (UK) (collectively, “Mediaocean UK Entities”) on combatting forced labour in our business and in our supply chain. The term “forced labour” used in this policy includes slavery, servitude, any type of forced or compulsory labour and trafficking for the purposes of exploitation.
We oppose the use and exploitation of forced labour and we expect all those who work for us or on our behalf to share our zero-tolerance approach. Eradicating forced labour is consistent with our ethical principles and is important to protect our reputation, sustain investor and consumer confidence and secure our commercial position.
This policy applies to all those who work for us and those who work on our behalf, including employees, agency workers, casual and freelance staff.
Our responsibilities
Our board of directors (the “Board”) is responsible overall for ensuring that this policy and our annual slavery and human trafficking statement (see below) comply with our legal and ethical duties.
The General Counsel has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, answering queries on it and auditing internal processes aimed at ensuring that forced labour is not taking place in our business or our supply chains. The UK Controller is also responsible for preparing the annual statement and presenting it to the Board for approval.
The Modern Slavery Act 2015 requires commercial organisations over a certain size to publish a slavery and human trafficking statement each financial year, disclosing the steps an organisation has taken to ensure that slavery and human trafficking is not taking place in its supply chain or its business.
What we are doing
The majority of our procurement activities are related to the purchase from third party suppliers of IT equipment, office related materials, professional services, advertising services, sales operations, technology and intellectual property licensing, and product development, promotion,
and distribution. Contracting with suppliers, and diligence activities with respect to our suppliers, are conducted primarily by functions at the Mediaocean or Innovid corporate level.
We are confident that we employ no forced labour directly within our business. However, we regularly review that and also assess our supply chain with a view to ensuring that there is no use of forced labour within the supply chain.
We take the following steps to prevent, evaluate and address risks of forced labour in our supply chain:
- We contractually require our suppliers to comply with all applicable laws and regulations; and
- We consider the compliance of each supplier against this policy and applicable laws and regulations when awarding and/or renewing business with the supplier, including conducting a review of the supplier's business profile and examining various risk factors to determine whether the supplier is at risk for non-compliance with our policies and expectations.
Employee responsibilities
Managers are responsible for ensuring that this policy is applied within their area of responsibility.
Our employees are expected to be alert to any indicators of forced labour in our business or supply chain.
We do not tolerate any forced labour within our business. If you suspect that there has been a breach of this policy or if you have any concerns regarding the issue of forced labour in any part of our business or our supply chain, you should notify legal@innovid.com as soon as possible, or report it in accordance with our Whistleblowing policy as soon as possible.
Status of this policy
This policy is not part of any contract of employment and does not create contractual rights or obligations. It may be amended by us at any time.
Further actions and sign-off
We continue to remain vigilant to identify and mitigate the risk of forced labour in our business and supply chains and in particular continues to monitor our operations in higher risk jurisdictions.
This statement has been approved by the Boards of the Mediaocean UK entities. This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes the Mediaocean UK Entities' slavery and human trafficking statement thereunder.