Spring Studios Media Investment Limited and its subsidiaries

Modern slavery statement for financial year ending December 2021

According to the International Labour Organisation, there are some 21 million people worldwide subjected to forced labour. We do not tolerate forced labour either within our business itself or within our supply chain. We expect our supply chain (whether direct suppliers or those that directly or indirectly supply our direct suppliers) to share the same values.

Our Business

1. The Company operates on a Global capacity working in media representation services, supplying creative work to our clients.

2. As a result, we work with suppliers across multiple sectors. These sectors include, but are not limited, production and design companies, catering services, transport, recruitment agencies, hardware and software companies, legal, tax, health & safety advisors, brokers, insurers, office suppliers, security and facility management services.

We have reviewed our business and our supply chain. Neither we nor, to the best of our knowledge, our supply chain make use of forced labour. We have taken the following steps to assess and manage any risk that our supply chain may use forced labour:

• We have adopted a Supplier Code of Conduct.

• We expect our suppliers to comply with the Supplier Code of Conduct and to place similar expectations on their respective suppliers.

• When entering into arrangements with suppliers, suppliers undergo a supplier approval process in which we assess them from a qualitative and economic perspective. As part of that assessment, we are alert for any indicators of forced labour.

• We may impose contractual obligations on suppliers under which they:

• undertake to comply with our Supplier Code of Conduct;
• warrant that their business and, to the best of their knowledge, their own supply chain do not use forced labour;
• agree to provide us on request with responses to a self-assessment questionnaire regarding use of forced labour and steps they have taken to ensure it is not used by them or their supply chain;
• agree to permit us and third parties acting for us to inspect their facilities, records and practices, to have access to their personnel and to audit their business for the purposes of ensuring that they comply with these obligations and that there is no use of forced labour; and
• impose equivalent obligations on their own suppliers.

• We have reviewed statements published by our suppliers on use of forced labour to ensure that they in turn are taking what appears to us to be appropriate steps.

• We review our supply chains annually to evaluate forced labour risk and take appropriate steps to address any identified risks.

• We train personnel working with our supply chain on forced labour and the Supplier Code of Conduct, with a view to identifying and reducing the risks of forced labour in our supply chain