MODERN SLAVERY STATEMENT
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Getty Images has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Getty Images is a leading global provider of digital content comprising of images, video and music to over one million customers in almost every country in the world. Our digital content products and services do not involve the usual reporting issues around packaging, manufacturing supply chains and human rights for affiliated suppliers and workers; however, we fully support the aims of the UK's Modern Slavery Act 2015 and are committed to combatting modern slavery and human trafficking. Our values reflect our commitment to acting ethically and with integrity in all our business relationships.
OUR STRUCTURE, BUSINESS AND SUPPLY CHAINS
The Getty Images operating group of companies' ultimate parent company is Getty Images, Inc. Getty Images is US based, with operating subsidiaries in the UK and around the world. The terms "Getty Images"/ "the Group" as used in this statement, refer collectively to Getty Images, Inc. and its subsidiaries, including Getty Images International, Getty Images (UK) Limited and Getty Images UK DevCo Limited. The Group has approximately 1800 employees and operates on a global basis.
Getty Images is among the world's leading creators and distributors of award-winning still imagery, video, music, and multimedia products. The Group has numerous sources for the images and digital content we license to our customers, ranging from wholly owned content created by our staff photographers and contributors to content distributed through partnerships with photographic and video agencies and other large media companies. In addition, we have vendor relationships with suppliers for facilities, technology, financial services, and the provision of benefits for our employees.
We have adopted Codes of Conduct which set out the principles by which we conduct our business and with which we expect all employees, vendors, and business partners to comply. Our Code of Ethics, Code of Business Conduct and Corporate Compliance Program ("Codes of Conduct") sets out terms and conditions as required by law to provide a work culture that promotes equality, inclusion and respect in the workplace and allows for whistleblowing and other processes for raising grievances or concerns in the workplace. For all our employees, failure to comply with the provisions of our Codes of Conduct may result in disciplinary action or termination.
At Getty Images we consider it integral to our business to operate in an honest, trustworthy and transparent manner and we extend this approach in our relationships with business partners and vendors. We encourage and promote open and frank communication across our supply chain to ensure compliance with our Codes of Conduct, policies or applicable laws. On notification of non-compliance Getty Images acts appropriately and proportionately to bring a solution to either allow for corrective action or if necessary, terminate an agreement if a supplier is not adhering to contractual obligations or there is a blatant disregard for our policies or Codes of Conduct.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
Whilst we have not identified modern slavery as being a particular risk in our own business and supply chains, as part of our initiative to identify and mitigate risk we:
- Audit HR files in the UK to ensure we have right to work information for all employees, and comply with local legal requirements in territories outside of the UK;
- Include provisions within our due diligence questionnaires and terms of business with suppliers, which require compliance with all applicable laws, including modern slavery;
- Continue to review our supplier audit program to include modern slavery;
- Collaborate with vendors across internal functions and responding to their own due diligence processes; and
- Protect whistle blowers and deploy a dedicated whistleblowing hotline.
- Regarding our large suppliers or those operating in a high-risk territory/industry for modern slavery or human trafficking we have taken active steps to risk assess their business and ensure compliance with our principles and continue to monitor these supplier relationships and demonstrate vigilance.
Within Getty Images' own production, distribution, and supply of services we productively manage and control the Group's international working conditions in relation to hours of labour, pay rates and environment to ensure there is limited risk of modern slavery within our own business.
We shall annually review our practices, processes and procedures in relation to the Group's business operations and supplier engagement to ensure mitigation of risk of non-compliance with the Modern Slavery Act.
In the last financial year and as applicable to 2019, we continue to promote our leadership principles of transparency and integrity in everything we do. To maintain these principles we shall in 2019 implement training as part of the Group's onboarding process, alongside other compliance training, so new employees are aware of our due diligence policies and reporting procedures pertaining to modern slavery in our business and/or supply chain or any other derogatory or inhumane treatment they may become aware of across our Group or services. We train all employees on an ongoing basis, including training in 2019 on Leadership Principles and our Code of Business Conduct, aimed at improving risk identification across the Group targeting employees that deal with suppliers as part of their day to day.
Although we consider our digital content products and services to be low risk of non-compliance with the Modern Slavery Act, our continual audit and review of our supply chain allows us as a Group to operate responsibly, accounting for our business and supply chain to deliver with confidence digital content to our global customers.
This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes the Group's slavery and human trafficking statement for the financial year ending 31 December 2018.
This statement has been approved by: