Our client work

Effective marketing has the power to shape ideas and change behaviour. It can be a powerful tool to bring about positive change on social and environmental issues and to help brands, governments and NGOs achieve their sustainability goals. Given the power of marketing, it is essential that we meet high ethical standards in our work, have clear policies and procedures governing the way we operate and support our people to make the right decisions.

Fast read

Our goal

We seek to work with clients to engage citizens and consumers on sustainability issues, while minimising ethical risks to WPP and our clients.

We focus on:

  • Sustainability in marketing
  • Ethical standards
  • Human rights
  • Public policy and lobbying
  • Privacy and data security

Business value

Sustainability-related and social marketing services are an important part of our work and a growing source of revenue. Leading privacy practices enable us to access new business, to reduce financial, legal and reputational risks to the business and to comply with regulation such as the EU’s General Data Protection Regulation (GDPR).

Sustainability impact

Our communications and marketing expertise can help to increase the market for products and services with sustainability credentials.

Challenges and dilemmas

We work in 112 countries around the world against a background of fast-moving technology. We need to understand the local context, while maintaining consistently high standards in relation to ethical conduct and privacy and data security in all our markets and when acquiring new businesses.

We rely on our people and leaders to make the right judgement in relation to ethical issues in client work and such issues are not always easy to identify or resolve.

Management approach

The WPP Code of Business Conduct provides the ethical framework for WPP and our companies. It summarises our values, principles and key points of policy that apply to everyone at WPP. It is supported by more detailed policies in areas such as anti-bribery and corruption, hospitality and gifts, facilitation payments and the use of third-party advisors as well as our Human Rights Policy Statement, Data Code of Conduct and Sustainability Policy. Our companies incorporate these principles into their own policies and procedures.

Responsibility for ethics and compliance lies with our Group chief counsel who reports directly to our CEO.

Senior managers in all our companies and our business and supplier partners are asked to sign a copy of the WPP Code of Business Conduct each year to confirm they will comply with its principles.

External frameworks

GRI indicators in this section: G4-2 (M), G4-15, G4-16, G4-34(M), G4-56(M), G4 – 58, G4-HR2 (M), G4-HR6, G4-SO4, G4-SO6, G4-PR7 (M), G4-PR8

Global Compact Principles: 1, 2, 3, 4, 5, 6, 9, 10

Progress on our KPIs in 2017

         

£2.11 billion revenue from clients who engaged with WPP on sustainability Increased
188,100 employees completed refreshed anti-bribery and corruption training since 2016 Increased
187,100 completed our ethics training since 2016. Increased
Over 208,000 employees completed online Privacy and Data Security Awareness training since 2016
Increased

Key:

Increased Increased

Sustainability in marketing

We work with clients on sustainability across our disciplines. This work is growing in importance as more of our clients seek to develop brands with purpose and to integrate social and environmental values into their communication. This can include:

  • Data investment management: Providing insight into future trends, changing consumer attitudes to social and environmental issues and testing the impact of sustainability strategy and communications approaches.
  • Brand consulting: Integrating social and environmental values into brand and business strategy.
  • Consumer and citizen communications: Helping clients communicate credibly with consumers and citizens on sustainability. This can include cause-related marketing that brings together brands with charities and social marketing campaigns for NGOs and governments addressing health, safety and environmental issues.
  • Internal communications: Engaging internal audiences on social and environmental issues.
  • Stakeholder communications: Our public relations and public affairs companies help clients to communicate with regulators, the media, NGOs and the public on sustainability issues.

Social marketing

Social marketing raises awareness of issues of public interest – including health, safety and the environment – and creates behaviour change for the benefit of society as a whole. We work with many clients including governments and NGOs on social marketing campaigns.

Our Government & Public Sector Practice brings together our best thinking and expertise for policy makers and communicators in national and local government, public institutions and international organisations (see rapturecity.info/govtpractice/). Our companies work for the public sector in more than 70 countries.

Cause-related marketing

We help clients to partner with charities through cause-related marketing campaigns. These can be effective in raising the profile of the brand while engaging consumers and raising funds to benefit social and environmental causes.

Recent client work

​Ethical standards and culture

We aim to create a consistent culture across WPP companies and locations, helping our people to apply our standards and make the right decisions. Our policy framework is supported by training and guidance for our people and the work of our HR, compliance, audit and sustainability teams.

The WPP Code of Business Conduct provides the ethical framework for WPP and our companies. It summarises our values, principles and key points of policy that apply to everyone at WPP. It is supported by more detailed policies in areas such as anti-bribery and corruption, hospitality and gifts, facilitation payments and the use of third-party advisors as well as our Human Rights Policy Statement and Sustainability Policy. Our companies incorporate these principles into their own policies and procedures.

All our people complete online ethics training, which helps them deal with a wide range of ethical, social and environmental subjects they may encounter in their work. Topics covered include diversity, human rights, conflicts of interest and avoiding misleading work.

Our online training on anti-bribery and corruption covers the Foreign Corrupt Practices Act and UK Bribery Act on issues such as hospitality and gifts, facilitation payments and the use of third-party advisors.

Training is updated every 2-3 years and our people are required to repeat the training following each update. Over 188,100 people have completed our anti-bribery and corruption training and over 187,100 have completed our ethics training since the last update in summer 2016.

Management and compliance

Responsibility for ethics and compliance lies with our Group chief counsel. We have a Group-level committee that meets regularly to discuss ethical and compliance issues and new risk areas. Committee members include the Group chief counsel, Group privacy officer and deputy general counsel, head of internal audit, Group finance director and the head of talent. The committee met twice in 2017.

Senior managers in all our companies and our business and supplier partners are asked to sign a copy of the WPP Code of Business Conduct each year to confirm they will comply with its principles.

Breaches or alleged breaches of our Code are investigated by the WPP Legal and Internal Audit teams. Our people can report concerns or suspected cases of misconduct in confidence through our third party-managed Right to Speak facility, overseen by our legal and internal audit departments. Our people can access it via phone or email and report concerns in their local language. It is publicised through induction packs, the Group intranet, the WPP Policy Book and our ethics training. There were 106 calls made via Right to Speak during 2017, all of which were followed up, investigated where appropriate and reported to the Audit Committee.

Associates, affiliates and acquisitions

We expect associate companies (those in which we hold a minority stake) and affiliate companies (preferred partners to whom we may refer business) to adopt ethical standards that are consistent with our own.

Our due diligence process for acquisitions and expansion into new markets includes a review of ethical risks including those relating to bribery and corruption, human rights or ethical issues associated with client work.

Acquired businesses must adopt our policies and their people must undertake our ethics training within a month of joining the Group. This is included in the integration plan agreed before the acquisition is finalised and we monitor progress after acquisition.

Compliance with marketing standards

We expect our companies to comply with all relevant legal requirements and codes of practice for marketing standards in the work they produce for clients. A small number of the campaigns we produce give rise to complaints, some of which are upheld by marketing standards authorities. Our companies take action where needed to prevent a recurrence.

Our agencies have policies and processes to ensure that online advertising does not appear on sites with illegal, illicit or unsuitable content. We work with suppliers and other partners on this issue and support initiatives such as The City of London Police Operation Creative. In 2017, GroupM participated in the EU Commission ‘Follow the Money – Online Advertising’ IPR enforcement expert meetings.

Ethical decisions in our work

Our work for clients can sometimes raise ethical issues, for example, work for government clients, work relating to sensitive products or marketing to children. We have a review and referral process for work that may present an ethical risk.

Before accepting potentially sensitive work, our people are required to elevate the decision to the most senior person in the relevant office and then to the most senior executive of the WPP company in the country concerned, who will decide if further referral to a WPP executive is required. Our people are trained on this referral process during our ethics training.

Companies also have copy-checking and clearance processes through which campaigns are reviewed by the legal team before publication. Requirements are particularly comprehensive in sectors such as pharmaceutical marketing which are highly regulated.

Human rights

Respect for human rights is a fundamental principle for WPP. We aim to prevent, identify and address any negative impacts on human rights associated with our business activities. We look for opportunities to positively promote human rights, including through our pro bono work.

Our human rights policy statement  summarises our approach. It reflects international standards and principles, including the International Bill of Human Rights, the UN’s Guiding Principles on Business and Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and the Children’s Rights and Business Principles.

We are a member of the United Nations Global Compact and committed to its 10 principles, including those relating to human rights. See Global Compact Index.

Our direct and indirect human rights impacts

Direct and indirect human rights impacts. Direct influence: our people. Indirect influence: on-site contractors. Indirect influence: workers in our supply chain. Indirect influence: citizens and consumers impacts by our campaigns

  • Direct impact
  • Indirect influence
  • Indirect influence
  • Indirect influence

Our main human rights impact is as a major employer. We aim to embed respect for human rights into our employment practices. This includes encouraging diversity, preventing discrimination, providing safe workplaces, recognising the rights of our people to freedom of association and collective bargaining, and not tolerating harassment or any form of forced, compulsory or child labour. Human rights is included in our compulsory ethics training.

We work with supplier partners on human rights and set clear standards through our Supplier Code of Conduct.

We do not tolerate any form of modern slavery, forced labour or human trafficking in any part of our business or supply chain. See our Modern Slavery Act Transparency Statement for more information.

Living wage

In the UK we are now a living wage employer accredited by the Living Wage Foundation. This means that WPP, the parent company, and all our UK companies pay the voluntary living wage to our people and all on-site contractors such as cleaning, security and catering staff in the UK. This exceeds the UK’s statutory national living wage.

Our policy is not to offer unpaid internships and apprenticeships anywhere in the world.

Operating in sensitive countries

We use a variety of sources to understand and manage any risks associated with different countries of operation, including the Transparency International Corruption Index, Human Rights Watch country reports and any relevant governmental guidance. We comply with all relevant sanctions regimes.

Human rights and marketing

Client marketing campaigns can have an impact on human rights and, where relevant, we work with our clients on these issues. This includes protecting children’s rights in relation to marketing. WPP companies will not undertake work designed to mislead on human rights issues.

Our companies provide creative services to organisations involved in protecting and promoting human rights, often on a pro bono basis. This is our main opportunity to positively promote human rights. Many examples are included in our Pro bono book, rapturecity.info/probono/2017/.

Public policy and lobbying

We are involved in public policy activity in two ways. Our public affairs businesses carry out work for clients, including direct lobbying of public officials and influencing public opinion. On occasion, we also engage in the public policy process on issues that affect WPP and our companies.

We believe that business can make a valuable contribution to the debate on regulation and government policy. However, to protect the public interest, it is important that business lobbying is conducted with honesty, integrity and transparency.

Our public affairs companies include: Burson Cohn & Wolfe and its affiliates: Prime Policy Group, Direct Impact and Penn Schoen Berland; Finsbury; Glover Park Group; Hill+Knowlton Strategies and its affiliates: Dewey Square Group and Wexler & Walker Public Policy Associates; OGR; Benenson Strategy Group. The majority of their work takes place in the US and the EU, although many clients are multinational businesses.

Our standards

Our political activities are governed by our Code of Business Conduct and other ethical policies, which commit us to acting ethically in all aspects of our business and to maintaining the highest standards of honesty and integrity. These apply to all employees, directors and entities.

Read our Political Activities and Engagement Policy.

Many of our companies are members of professional organisations and abide by their codes of conduct. Examples include the UK’s Association of Professional Political Consultants (APPC), the self-regulatory body for UK public affairs practitioners, and the European Public Affairs Consultancies’ Association (EPACA) the representative trade body for public affairs consultancies working with EU institutions.

WPP companies comply with all applicable laws and regulations governing the disclosure of public affairs activities. In the US, this includes the Lobby Disclosure Act and the Foreign Agent Registration Act, which are designed to achieve transparency on client representation and require lobby firms to register the names of clients on whose behalf they contact legislators or executive branch personnel. A number of our companies are listed on the voluntary EU Transparency Register of lobbying activities.

It is WPP’s practice that those of its US companies whose sole or primary business is lobbying have representatives of both major political parties among senior management.

We will not undertake work that is intended or designed to mislead. We do not knowingly represent ‘front groups’ (organisations which purport to be independent NGOs but are controlled by another organisation for the purpose of misleading) and seek to ensure we are aware of who the underlying client is before taking on work.

Mark Linaugh, chief talent officer, has overall responsibility for our public affairs practices and is a member of our Ethics Committee. Ultimate responsibility for our political activities rests with our Group chief executive.

Any associates carrying out political activities on our behalf are expected to comply with our Code of Business Conduct and other relevant policies.

Political contributions

Our policy on political donations is included in the WPP Policy Book that applies to all WPP employees and companies worldwide. Our internal audit team assesses compliance with our Policy Book as part of its Group-wide audit program. WPP the parent company does not make political contributions. WPP companies are not permitted to make cash political donations. Any other donations require prior approval of an executive director. This includes attendance at political party conferences and events which are classed as political contributions in some jurisdictions.

Political action committees

In countries where it is consistent with applicable law, individuals working at WPP companies may make personal voluntary political contributions directly to candidates for office. Several of our businesses, including Burson Cohn & Wolfe/Prime Policy, Glover Park Group, Hill+Knowlton Strategies and Wexler & Walker, also maintain political action committees (PACs) which accept voluntary donations from their people to support political candidates. During 2017 and early 2018, around $172,000 was given through these PACs to federal candidates.

Lobbying and political advocacy

We occasionally contribute to the debate on public policy issues relevant to our business, sometimes operating through our public affairs companies. For example, we support a Brexit deal that allows freedom of movement for qualifed employees and we are working with other businesses and the CBI to engage with the UK Government on this issue.

We engage in partnerships and advocacy on sustainability issues, for example, through the Common Ground initiative in support of the UN Global Goals, see Common Ground. We participated in the Business Against Slavery Forum in partnership with other businesses and the UK Government.

We gave evidence to a number of Government committees during 2017 in the UK. Bethan Crockett, senior director of brand safety and digital risk at Group M, gave evidence to the Select Committee on Digital Culture Media and Sports inquiry on fake news. Sir Martin Sorrell gave evidence to the House of Lords advertising industry inquiry. Our companies also contribute to public debate in areas where they have expertise and a special interest – our digital and research companies, for example, are involved on privacy and data protection issues.

We follow Government rules in relation to ‘cooling-off’ periods for people joining WPP from public office or the public sector.

Membership of trade associations

We are members of trade associations, industry groups and memberships organisations which undertake lobbying activity on behalf of their members.

At a parent company level our memberships in the US are the American Benefits Council, British American Business Inc, The Business Council, Business Roundtable, Council on Foreign Relations, Northeast Business Group on Health and the Wall Street Journal CEO Council. In the UK they are the All Party Parliamentary Corporate Responsibility Group, British American Business London Transatlantic Council, Business Disability Forum, CBI, Chambre de Commerce Française de Grande Bretagne, China Britain Business Council, Institute of Business Ethics, PARC, Trilateral Commission, Women on Boards and the World Economic Forum.

Memberships at an operating company level include the local advertising, PR, public affairs, market research or other relevant industry association as well as national chambers of commerce and business councils.

Privacy and data security

WPP companies work with many categories of data and we use the term data in its broadest sense. We include within this definition client data, consumer data and all information and data related to the operation of our businesses.

We have rigorous privacy and data security standards and procedures governing how we collect, use and store this data to protect consumer privacy and reduce risks to our business.

We further strengthened our procedures in 2017 to ensure we comply with the requirements of the EU’s General Data Protection Regulation (GDPR) across our business.

Our policies and standards

Our Data Code of Conduct applies to all WPP companies and provides a clear framework for the responsible collection, management, use and protection of data. It is supported by our global IT security, privacy and social media policies and our security standards, known as our General Computing Controls, which are based on ISO 27001. These standards will include GDPR from 2018. Where necessary, we are reviewing and updating our policies to ensure they reflect the GDPR requirements.

We have appointed a Group chief privacy officer to lead our work on privacy and partner with our companies and security and audit teams to promote privacy best practices.

Privacy leads in our companies oversee the implementation of our policies at a local level. They report progress to the Group via our Group chief counsel, Group chief privacy officer and Group finance director.

Any supplier who collects, manages or stores employee, consumer or client data on behalf of WPP, our companies and our clients must have the right data security and privacy standards in place. We conduct due diligence on data suppliers and embed privacy requirements in our supplier contracts, which include reference to GDPR.

Training and resources

Our SAFER DATA platform provides information, guidance and resources to help our people understand privacy risks and to apply our policies to their work.

We have added a range of resources to help our companies comply with the GDPR and engage with clients and suppliers on privacy. These include our GDPR toolkit, which contains guidance notes, model data protection contract clauses, template privacy impact assessment tools, policy templates and other resources.

The portal also includes a ‘SAVEMYDATA’ reporting tool, to allow our people to raise concerns and questions they have about data issues direct with our in-house legal teams.

Privacy and data protection are everyone’s responsibility. All employees in the Group complete our mandatory global online Privacy and Data Security Awareness training. This has been completed by 208,419 people since 2016.

We have also conducted over 50 face-to-face training sessions with our companies and country leads on GDPR, in Europe, Asia and North America.

Managing privacy risks in our companies

We take a risk-based approach to managing privacy, prioritising engagement with our companies who collect and use most personal data.

Our annual Data Health Checker survey helps us to identify privacy risks and assess data security practices in our companies. A summary of results for 2017 will be published here in due course.

Our internal audit team reviews privacy risks and practices as part of its Group-wide audit program. In 2018, we will begin auditing company compliance with specific GDPR controls, mandated by our Group chief privacy officer and legal team.

Each of our major company networks now has a GDPR compliance plan for assessing and managing data risks, which includes: conducting supplier due diligence; updating policies and procedures; and training employees.

Some networks have established a GDPR Steering Committee to oversee progress. In addition, in 2017, we created new senior privacy officer roles in our Kantar, GroupM and Wunderman networks to lead their work on GDPR compliance.

Our companies are embedding a range of privacy best practices to align with the GDPR, such as ensuring privacy impact assessments are conducted where appropriate and embedding privacy by design principles within our systems.

We have consolidated and outsourced management of our IT systems and infrastructure across WPP companies. This allows consistency in data security practices.

Working with clients and others

We partner with clients, industry organisations and peer companies on privacy issues. For example, we are working with the Internet Advertising Bureau (IAB) Europe to help develop its GDPR Transparency & Consent Framework.

GDPR also represents an opportunity for the Group to work with clients to help them embed privacy best practice within their marketing and campaign strategies. This includes, for example, the integration of privacy by design principles into deliverables and ensuring GDPR best practice is adopted for managing consent.

WPP DATA CODE OF CONDUCT

Our principles

WPP, its companies and its people are committed to responsible collection, management, use and protection of data.

WPP recognises its obligations to all its stakeholders including share owners, clients, its own people, suppliers and consumers.

WPP works with many categories of data and uses the term data in its broadest sense. We include within this definition client data, consumer data and all information and data related to the operation of our businesses.

Our practices

  • We will be transparent with consumers.
  • We will treat data in accordance with all applicable laws, regulations and treaties.
  • We will implement fair and reasonable data policies and procedures.
  • We will treat data as confidential.
  • We will understand not only what data we hold but also its relevance to stakeholders.
  • We will secure, collect, process, use and store data appropriately.
  • We will ensure that data is retained appropriately.
  • We will implement necessary and appropriate technical measures to secure data.
  • We will delete data when required to do so.
  • We will ensure our people understand their role in upholding these principles and practices.