Last updated: June, 2018
We at Omnicom Media Group Holdings Inc. (“OMG”), respect your concerns about privacy. This Online Privacy Notice applies solely to information we obtain through the website on which a link to this Online Privacy Notice appears (“Site”). This Online Privacy Notice describes the types of information we obtain through the Site, how we may use the information, with whom we may share it and the choices you may have regarding our use of the information. We also describe the measures we take to safeguard the information and tell you how to contact us about your information and our privacy practices.
OMG consists of a network of affiliates, including but not limited to Accuen, Hearts & Science, OMD, PHD, Outdoor Media Group, Optimum Sports/Fuse, Content Collective, Pathway and Resolution Media. This Online Privacy Notice only applies to the affiliates on whose website this Online Privacy Notice appears. For the privacy practices of our affiliates, you should visit their websites to review their own privacy notices.
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INFORMATION WE OBTAIN
We may obtain the following types of personal information when you choose to provide it through our Site:
- Contact information, such as your name, postal address, email address and telephone number;
- Site information – personal information you provide on or through our Site; and
- Biographical information – such as information about your education, work and military history, legal work eligibility status, and other information relevant to specific jobs for which you may apply.
In addition, when you visit our Site, we may collect certain information by automated means, such as cookies and web beacons. The information we obtain in this manner may include IP address, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our site, and dates and times of website visits. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Through these automated collection methods, we obtain “clickstream data,” which is a log of content on which a visitor clicks while browsing a website and other actions taken on such website. As the visitor clicks through the website, a record of the action may be collected and stored. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Site.
An example of such third party is Google Analytics, which we use to collect and analyze demographic and other information, and through which Google will collect certain information to be used according to Google’s privacy practices. To opt-out of the use of Google Analytics, click here.
Information about our cookie practices is available here. To the extent required by applicable law, we will obtain your consent before collecting information using cookies or similar automated means.
HOW WE USE THE INFORMATION WE OBTAIN
We use the information we obtain through the Site to:
- respond to and communicate with you about your requests, questions and comments;
- operate, evaluate and improve our business (including developing new products and services; managing our communications; determining the effectiveness of our sales, marketing and advertising; analyzing and enhancing our products, services and Site; and performing accounting, auditing, billing, reconciliation and collection activities);
- perform data analyses and other processing (including market and consumer research and trend analysis);
- protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
- comply with and enforce applicable legal requirements, relevant industry standards and our policies.
In addition, we use information collected online through cookies, web beacons and other automated means for purposes such as (i) customizing our users’ visits to our Site and (ii) providing services to you. We also use this information to help diagnose technical and service problems, administer our Site, identify users of our Site, and gather demographic information about our users. We use clickstream data to determine how much time users spend on web pages of our Site, how users navigate through our Site, and how we may tailor our Site to better meet the needs of our users.
We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
INFORMATION WE SHARE WITH THIRD PARTIES
We do not sell or otherwise share personal information about you, except as described in this Online Privacy Notice.
- We share personal information with third parties who perform services on our behalf. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.
- We also share the personal information we obtain with our affiliates and subsidiaries for the purposes described in the section of this Online Privacy Notice called “How We Use the information We Obtain.”
- With respect to personal information received or transferred pursuant to the Privacy Shield Framework, Omnicom Media Group is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials based on a lawful disclosure request, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
- We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, bankruptcy or liquidation).
We offer you certain choices about how we communicate with you and what information we collect from you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as indicated in the How To Contact Us section of this Online Privacy Notice.
We have put in place reasonable physical, electronic and managerial procedures to safeguard the information we collect; however, due to the inherent open nature of the Internet, we cannot guarantee that all information will be free from unauthorized access by third parties, such as hackers, and your use of the Site demonstrates your assumption of this risk.
We will only retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for satisfying any legal, accounting or reporting requirements or to comply with our data retention practices.
If you are located in the European Union with rights under the General Data Protection Regulation (“GDPR”), the following additional sections apply:
1) Grounds for Using Your Personal Information: we rely on the following legal basis to process your personal information:
- It may be necessary for us to use and disclose your personal information for the performance and fulfillment of the contract between us and to provide you with our services;
- We may use and disclose your personal information where it is necessary for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests;
- If you specifically consent to certain uses of your personal information, we may use your personal information in a manner consistent with that consent; and
- We will also process, transfer, disclose and preserve personal information when we have a good faith belief that doing so is necessary.
2) If applicable pursuant to the GDPR, you have the right to withdraw previously provided consent for our processing of your personal information by contacting us at [email protected] Such individuals also have the following rights:
- Right to access – This right allows individuals to obtain confirmation that his or her personal information is being process and allows individuals to request details of the processing of his or her personal information, including, without limitation, categories of recipients to whom the personal information have been or will be disclosed and purposes of processing.
- Right to rectify – This right allows individuals to rectify any inaccurate personal information about him or her.
- Right to restrict processing – This right allows individuals to block or suppress processing of personal information under certain circumstances.
- Right to be forgotten – This right is also known as the “right to erasure.” It is an individual’s right to have personal information erased or to prevent processing in specific circumstances.
- Right of data portability – This right allows individuals to move, copy or transfer personal information from one place to another in a secure manner without interrupting the integrity and usability of the information.
- Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.
To exercise any of the following rights, you may contact us at [email protected]
Some of the personal information we collect about you through the Site will be transferred to countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your personal information to other countries, we will protect that information as described in this Online Privacy Notice and will comply with applicable legal requirements.
LINKS TO OTHER WEBSITES
Our Site may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with OMG. Linked websites typically have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with OMG, any use of those websites, or the privacy practices of those websites.
UPDATES TO OUR ONLINE PRIVACY NOTICE
This Online Privacy Notice may be updated periodically. We will post a prominent notice on our Site to notify you of any significant changes to our Online Privacy Notice and indicate at the top of the notice when it was most recently updated.
HOW TO CONTACT US
If you have any questions about this Online Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us by email at [email protected] or write to us at:
Omnicom Media Group Holdings Inc.
Attn: Privacy Counsel
195 Broadway, Floor 28
New York, NY 10007
If you are in the European Union, please contact:
Omnicom Media Group
Attn: General Counsel
10 Regents Wharf
Tel: +44 (0)203 349 6777
Supplier Code of Conduct
1. Our Values
- 1.1 Omnicom Media Group Europe Limited and each of its subsidiaries (hereinafter collectively referred to as “we, “our”, “us”), are committed to achieving a standard of excellence in every aspect of our business.
- 1.2 We always strive to work to the highest professional standards and comply with all laws, rules and regulations relevant to our business. Our corporate responsibility strategy aims to improve the impact of our business on society. We expect the same high standards from those businesses with which we work. A reliable and ethical supply chain is critical for our business. Consequently, we expect members of our supply chain to conduct their business activities ethically and responsibly, with integrity, honesty and transparency and in compliance with all applicable laws, rules and regulations, and, where the provisions of law and this code address the same subject, to apply that provision which affords the greater protection. We require that all members of our supply chain endorse our values by operating in compliance with this Supplier Code of Conduct.
- 1.3 As a minimum, we expect all of our suppliers to meet the standards and promote the principles outlined in this Supplier Code of Conduct, and we expect all of our suppliers (hereinafter referred to as “you”, “your”) to hold their own supply chain to the same standards.This Supplier Code of Conduct is not exhaustive and this code should not be used to prevent companies from exceeding these standards.
2. Principles of Supplier Conduct
- 2.1 Anti-DiscriminationYou shall not discriminate against any worker based on age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex, sexual orientation or any other legally protected characteristic, in hiring or other employment practices.
- 2.2 Anti-Harassment and abuseYou shall commit to a workplace free of harassment and abuse and shall not threaten workers with, or subject them to, harsh or inhumane treatment. You shall uphold the human rights of workers and treat your workers with dignity and respect. You shall ensure that workers have a mechanism to report grievances and that your business encourages and facilitates open communication between management and workers.
- 2.3 Underage WorkersYou shall ensure that no underage worker is used in the production or distribution of your goods or services. You shall employ only workers who meet the applicable legal minimum working age, except that in no event shall you employ any person who is under the age of 16 even if local law permits otherwise. You shall also comply with all other applicable laws in relation to your workers.
- 2.4 Working hours, Wages and BenefitsYou shall set working hours, wages (including but not limited to shift pay and other allowances) and over-time pay in compliance with applicable laws. Your workers shall be paid at least the minimum legal wage or a wage that meets local industry standards, whichever is greater. All deductions from wages should be lawful and with the expressed permission of the employee.
- 2.5 Freedom of AssociationYou shall freely allow workers lawful rights to associate with others, form and join organisations of their choice, and bargain collectively, without interference, discrimination, retaliation or harassment.
- 2.6 Employment StatusYou shall employ workers, with a written contract of employment, who have complied with all relevant immigration regulations and who lawfully live and work in the country in which you operate. You shall ensure that all workers provide satisfactory proof of identity to you and that employment by you of your workers does not breach any laws, rules or regulations.Your employees should be free to leave their employment after giving reasonable notice and are not required to lodge deposits or payments (in cash or other kind) with their employers.There should be no forced, bonded or involuntary labour.
- 2.7 Health and SafetyYou shall provide and maintain a safe work environment and integrate sound health and safety management practices into your business. You shall have a system for workers to report health and safety incidents without fear of reprisal, as well as a system to investigate, track, and manage such reports, and implement required corrective action. You shall obtain, keep current, and comply with all required health and safety permits, licences and consents.Suppliers must report to us any breach of the environmental, social or ethical rules set forth in this Supplier Code of Conduct,
- 2.8 WhistleblowingYou shall have clear policies and procedures in place so that workers may report concerns about wrongdoing in their workplace without being victimised or dismissed. You shall also comply with all other applicable laws in relation to whistleblowing.
- 2.9 Prevention of Modern Slavery and Human TraffickingYou shall take reasonable steps to ensure that modern slavery and human trafficking is not taking place in your supply chains or in any part of your business. Within 20 days of request, you shall provide to use a modern slavery and human trafficking report setting out the steps you have taken to ensure that modern slavery and human trafficking is not taking place in any of your supply chains or in any part of your business. This may include, to the extent relevant, information concerning:
- (a) your business structure and supply chain;
- (b) the policies you have adopted to ensure there is no modern slavery, including human trafficking, forced or indentured labour, slavery or servitude, within your business;
- (c) the training and other measures used to ensure appropriate policies and procedures are applied;
- (d) the due diligence and monitoring conducted by your business to understand the relevant risk areas and confirm that no such behaviour is occurring;
- (e) a confirmation that no modern slavery issues have been identified in your business or supply chain in the last year;
- (f) to the extent any potential issues concerning modern slavery (including human trafficking, forced or indentured labour, slavery or servitude) have been identified within your business, the circumstances surrounding those issues and the steps you have taken to remedy such issues; and/or
- (g) documents evidencing the information provided in relation to the matters set out in this paragraph 2.9.
- 2.10 EnvironmentYou shall develop, implement and maintain environmentally responsible business practices. You shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle all of your waste. You shall obtain, keep current and comply with all required environmental permits, licences and consents and comply with any reporting requirements. You shall carry out your operations with care for the environment and comply with all applicable environmental laws and regulations.
- 2.11 Ethics
You shall always be ethical in every aspect of your business, including relationships,practices, sourcing and operations.
- 2.12 Compliance with LawYour business activities shall comply with all applicable laws and regulations in the countries and jurisdictions in which you operate.
- 2.13 Anti-BriberyYou shall not engage in corruption, extortion, embezzlement or bribery to obtain an unfair or improper advantage. You shall not provide or receive anything of value to obtain an improper business advantage or favourable treatment or exert undue influence, including offering, giving, asking for or taking any form of potential bribe or kick-back. This prohibition extends to payments and gifts of cash or in kind, made directly or through others. You must not offer any potentially illegal payments to, or receive any potentially illegal payments from, any customer, supplier, their agents, representatives or others. This includes a prohibition on facilitation payments intended to expedite or secure performance of a routine governmental action such as obtaining a visa or customs clearance, even in locations where such activity may not violate local law. You shall abide by all applicable anti-corruption laws and regulations of the countries in which you operate, including the UK Bribery Act 2010 and applicable international anti-corruption conventions.
- 2.14 Disclosure of InformationYou shall accurately record information regarding your business activities, employment, health and safety, and environmental practices and shall disclose such information, without falsification or misrepresentation, to all appropriate parties and as required by law. You shall maintain accurate financial books and business records in accordance with all applicable legal and regulatory requirements and accepted accounting practices.
- 2.15 Competition and Anti-TrustYou must comply with all applicable competition laws (sometimes called “antitrust laws”). These laws prohibit formal or informal understandings, agreements or arrangements among competitors that unfairly restrict competition. You must not fix prices, rig bids with your competitors or participate in a cartel. This includes a prohibition on exchanging current, recent or future pricing information with competitors.
- 2.16 Intellectual Property RightsYou shall respect intellectual property rights and shall not knowingly infringe the intellectual property rights of any third party. You shall manage technology and know-how in a manner that protects intellectual property rights.
- 2.17 Information SecurityYou must comply with applicable data privacy laws and must protect the confidential and proprietary information of others, including personal data, from unauthorised or unlawful processing, access, destruction, use, modification and disclosure, and against accidental loss or destruction, or damage through appropriate technical and organisational measures including physical and electronic security procedures. You are expected to take the necessary information security measures, for both computer systems and portable electronic devices, to protect against malware and unauthorised disclosure of any proprietary information.
- 2.18 Management Systems and CSR ResponsibilitiesYou must maintain sound management systems to identify and mitigate operational risks, and facilitate continuous improvement. You shall develop a company statement affirming your commitment to high standards of social and environmental responsibility, ethical conduct, and continuous improvement. You shall identify a company representative(s) responsible for ensuring implementation and periodic review of your management systems. You shall have a Corporate Social Responsibility (CSR) representative who has the responsibility to manage social and environmental compliance requirements for your business.
- 2.19 Risk Assessment and ManagementYou shall develop and maintain a process to identify employment and human rights, health and safety, environmental, business ethics, and legal compliance risks associated with your operations, determine the relative significance of each risk, and implement appropriate procedures and controls to minimise the identified risks.You shall have written standards, performance objectives, targets, and implementation plans, including periodic assessments of performance against those objectives. You shall perform periodic evaluations of your facilities and operations, and the facilities and operations of your subcontractors that provide goods or services to us to ensure compliance with this Supplier Code of Conduct. You shall permit our representative to periodically evaluate your facilities and operations, and those of your subcontractors, to the extent they are providing goods or services to us. You shall maintain appropriate documents and records to ensure regulatory compliance.
- 2.20 SubcontractingYou shall not use subcontractors for the provision of goods or services to us without our prior written consent, and in the event such prior written consent is given by us, you shall require the subcontractor to enter into a written commitment with you to comply with this Supplier Code of Conduct.
- 2.21 ConfidentialityYou shall safeguard our information by keeping it confidential, secure, limiting access, and avoiding discussing or revealing such information in public places. These requirements extend even after the conclusion of your business relationship with us.
- 3.1 This Supplier Code of Conduct is intended to promote a culture within our supply chain that complies with not only the letter, but also the spirit, of all applicable laws, rules and regulations.
- 3.2 You should refer to the principles set out in this Supplier Code of Conduct when ethical and compliance issues arise. Each of the principles in this Supplier Code of Conduct is fundamental to how we do business. However, this Supplier Code of Conduct cannot anticipate every possible instance in which an ethical issue may arise, and so it aims to reinforce the ethical and responsible way in which we require you to conduct your business and the integrity, honesty and transparency which is required in your operations.
Omnicom Media Group Europe Limited Statement on the Modern Slavery Act
This statement, which has been approved by the Board of Omnicom Media Group Europe Limited, is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our modern slavery and human trafficking statement for the financial year ending 31 December 2017.
This statement is made on behalf of Omnicom Media Group Europe Limited, and each of its subsidiaries listed at the end of this statement, (together “we”, “our”, “us”).
We foster a culture of collaboration and focus on investing in our people, protecting the environment and giving back to the communities in which we operate. We have a zero tolerance approach to any form of modern slavery and are committed to establishing effective systems and controls to safeguard against any form of modern slavery or human trafficking in our supply chain.
We are leading media services companies and our portfolios provide the best talent, creativity, technology and innovation to some of the world’s most iconic and successful brands. We always strive to work to the highest professional standards and comply with all laws, regulations and rules relevant to our business.
Our Supply Chain
Our key suppliers are media owners, media suppliers, research companies, technology service providers and software service providers. Modern forms of slavery and human trafficking are not prevalent in the industries in which these suppliers operate. We expect the same high standards as those to which we hold ourselves from those businesses with which we work.
We believe the nature of our work, our supply chains and their industries to be low risk in terms of modern slavery and human trafficking.
Our corporate responsibility strategy, codified in the Omnicom Group Code of Business Conduct, aims to improve the impact of our business on society and we are committed to ensuring that there is no modern slavery or human trafficking in any part of our supply chains or in any part of our business.
Our Supplier Code of Conduct reflects our commitment to acting ethically and with integrity in our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place anywhere in our supply chains. A copy of our Supplier Code of Conduct can be supplied upon request.
Our steps to implement our Supplier Code of Conduct are ongoing and since the date of our last Modern Slavery Act statement (in September 2017) our actions and findings have been as follows:
- we have updated existing websites so that they contain our Modern Slavery Act statement and Supplier Code of Conduct;
- we have communicated our Supplier Code of Conduct to our suppliers;
- we are continuing with our endeavour to negotiate express warranties and indemnities in our contracts with new suppliers regarding compliance with the Modern Slavery Act 2015 and our Supplier Code of Conduct;
- we have again identified that modern slavery and human trafficking are not prevalent in the industries of our key suppliers. We have also identified that our suppliers are not located in markets where there is a high risk and level of exposure to modern slavery and human trafficking; and
- although arranging training for our staff does not appear relevant (please see point 4 above), due to our zero-tolerance approach to any form of modern slavery, we feel that our staff would still benefit from having a clear understanding of (and ability to identify) forms of modern slavery and human trafficking, as well as how to combat them. We are therefore working to identify a third party to provide suitable training and guidance.
We continue to review our policies and processes in an effort to go beyond basic social and environmental regulations, to ensure the highest standards in our supply chain (as expected by our customers and the companies with which we work) and to ensure that no form of forced labour or slavery is present in our business or our supply chain.
This statement constitutes the modern slavery and human trafficking statement for Omnicom Media Group Europe Limited and the following subsidiaries:
- Drum Limited
- Hearts and Science Limited
- Mobile5 Media Limited
- OMD EMEA Limited
- OMD Group Limited
- OMG UK Limited
- PHD International Limited
- PHD Media Limited
CFO and Director
For and on behalf of Omnicom Media Group Europe Limited and the subsidiaries listed above.