Dentsu Group Supplier Code of Conduct
As a global marketing communications company servicing clients in more than 100 markets,
Dentsu Group Inc., and its subsidiaries (“dentsu”), are committed to conducting business tothe highest standards of integrity, ethics, and responsible business practices. Dentsu expects
its Suppliers to share these values.
Dentsu’s Supplier Code of Conduct (“Supplier Code”) outlines the expectations of its
Suppliers. A “Supplier” is any individual (Japan only), business, company or other entity thatprovides any kind of goods or service to dentsu, and includes the Supplier’s employees,directors, sub-contractors, and other representatives.
It is the responsibility of the Supplier to ensure that its employees, directors, sub-contractors,
and other representatives understand and comply with the Supplier Code. Suppliers must
maintain appropriate systems to ensure continuous compliance with this Supplier Code and todemonstrate their compliance.
Failure to meet the expectations in the Supplier Code may affect current and/or future businesswith dentsu.
Dentsu reserves the right to amend or replace the Supplier Code at any time. The latest versionof the Supplier Code is available at our website (Japanese, English). It is the responsibility of
the Supplier to check for updates. This Supplier Code replaces all previous versions of thedentsu Supplier Code of Conduct.
1.

Legal and regulatory compliance

Suppliers must always behave lawfully and ethically. Suppliers must respect and comply withall applicable local and international laws, regulations, and relevant industry codes in thecountries in which they operate when working with dentsu, including tax evasion, insider
trading, fraud, trade and import restrictions such as sanctions and embargoes, and moneylaundering.
Suppliers must conduct business fairly, transparently and with integrity. Applicablecompetition and anti-trust laws must be complied with. Suppliers must maintain fair andaccurate books and records, follow applicable invoicing and taxation requirements, andcomply with lawful and appropriate accounting practices and non-financial record keeping.
Suppliers must inform dentsu of changes to Supplier tax status which may impact dentsu.
2.

Confidentiality and security

Suppliers must keep information relating to dentsu and its clients (“dentsu Data”) strictly
confidential and secure. Suppliers must never disclose dentsu Data to any third party without
dentsu’s prior written permission or, when disclosure is required by law, regulation, or a court
order, without prior written notice (to the extent legally permitted).
Suppliers must have security policies and procedures in place to keep dentsu Data confidential
and secure, and all Supplier staff, sub-contractors and other representatives must be educatedon such policies and made aware of the importance of confidentiality. The Supplier may onlyDentsu Group Supplier Code of Conduct1

access dentsu Data for which such access has been granted and for the purpose which it hasbeen granted.
Suppliers must notify dentsu of any actual or suspected security incident relating to dentsu
Data to dentsu staff in charge of the business in dentsu Japan and to the mailreportsecurityincident@dentsu.com in three regions excluding Japan (“InternationalMarkets”).
3.

Respecting human rights and treating people with respect

Suppliers shall comply with all applicable human rights laws, statutes, regulations, codes andstandards, including without limitation the United Nations Universal Declaration of HumanRights, the International Covenant on Civil and Political Rights, the International Covenant on
Social, Economic and Cultural Rights, the UN Guiding Principles on Business and HumanRights and the ILO Declaration on Fundamental Principles and Rights at Work.
Dentsu requires its Suppliers to investigate whether there are any actual, or risks of, adverse
impacts on human rights or decent working conditions in their own operations, their supply
chain and other business relationships, inform us of any non-compliances and remedy theserisks or impacts accordingly.
In addition, dentsu expects suppliers to adhere to the following principles:(a) Forced labour
Suppliers must ensure that all employment is voluntary, and workers are not subject to forced
labour or any form of involuntary servitude. Employees must have the freedom to terminate
their employment in accordance with applicable laws and regulations.
Suppliers must not require employees to lodge deposits of money and shall bear all costs
related to the recruitment process. Suppliers must not require employees to surrender any
formal identification as a condition of employment.
Suppliers must provide all employees with a written employment agreement in a language thatthey can understand, containing clear terms and conditions of employment.
(b) Child labour
Suppliers shall not employ individuals below the legal minimum age for employment, as
defined by local laws and international standards. Adequate measures must be in place toverify the age of workers and prevent the use of child labour in any stage of production.
Any Supplier workplace apprenticeship programs must be for the educational benefit ofyounger people.
(c) Working Hours and Overtime
Working hours must not exceed the maximum set by local law, or the International Labor
Organisation’s standards on working hours – whichever is lower. Annual paid holiday and rest
periods must also be provided in accordance with local law, or the International Labour
Organisation’s Conventions on Holidays with Pay and Weekly Rest as a minimum.

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(d) Fair Wages and Benefits
Suppliers must ensure that all employees receive fair and competitive wages that meet or
exceed legal minimum requirements. In addition to basic wages, employees should receive any
legally mandated benefits, including overtime pay. Employees must receive information about
their employment conditions in writing.
(e) Non-Discrimination and Equal Opportunity
Suppliers must provide equal opportunities for employment and advancement to allindividuals, irrespective of race, gender, age, religion, disability, sexual orientation, maritalstatus, union membership, political affiliation, national origin, or any other protectedcharacteristic. Discrimination in hiring, promotion, or any other employment practice is strictlyprohibited.
(f) Freedom of Association and Collective Bargaining
Suppliers shall respect the rights of employees to freely associate, join or not join trade unionsof their choice, and engage in collective bargaining. No employee shall face discrimination orretaliation for exercising their rights to organize or participate in lawful collective bargainingactivities.
(g) No Harassment or Discrimination:
Suppliers must foster a work environment free from harassment, bullying, and discrimination,
including physical, verbal, sexual, emotional abuse, inhumane or degrading treatment, corporalpunishment, threats, or intimidation. All employees should be treated with respect and dignity,and measures should be in place to prevent and address any form of harassment ordiscrimination at any stage of employment.
(h) Migrant Workers
Suppliers must ensure migrant workers are treated with dignity and in accordance with thesame standards that apply to other employees and workers.
4.

Health and safety

Suppliers must comply with all relevant local health and safety laws and regulations and offer awork environment that is safe, conducive to good health, and helps prevent accidents, injuries
and work-related illnesses.
When on premises owned, leased, or managed by dentsu, the Supplier, its staff, subcontractors, and other representatives must adhere to all rules and regulations governing theoperation of the premises and interactions with individuals who have access to the premises.
These individuals may include dentsu employees, clients, other suppliers, or guests.
5.

Anti-bribery, corruption, and facilitation payments

Dentsu prohibits any form of bribery and corruption in all business dealings, in every countryaround the world, with both government and private sector parties. Dentsu has a zero-tolerance

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approach to bribery in any form, whether directly or through an agent, intermediary or any
Supplier.
Suppliers must comply with all applicable anti-bribery and corruption laws and regulations in
all countries in which they operate. Suppliers must not offer, give, receive, or request a bribe,
whether directly or indirectly, and must take reasonable steps to prevent others (who are actingon their behalf) from doing so.
Suppliers must not offer or give an incentive of any kind (including facilitation payments) to any
public official which would cause them to improperly fulfil their function or would be viewed as
corrupt activity. Suppliers must also implement and operate adequate procedures for
employees and workers to comply with applicable anti-corruption laws and regulations.
6.

Gifts & Hospitality

Suppliers must not offer or provide or accept any gifts and hospitality that are unlawful,
unethical, excessive or lavish, or otherwise inappropriate or would cause or could be seen tocause a person to improperly provide a business advantage or perform their function or
activities improperly or unlawfully. Suppliers must never offer or provide or accept any gifts inthe form of cash or cash equivalents, precious metals or gems or any other form readily
convertible to cash. Suppliers must not provide any gifts or entertainment to dentsu staff
during a tendering process. Suppliers may provide gifts, entertainment, and hospitality todentsu staff provided they serve a bona fide business purpose and are of appropriate value,
timing, and frequency.
7.

Data Protection

Suppliers must ensure that they comply with all applicable data protection laws, regulations,and industry codes relating to the data protection and privacy of dentsu Data. Suppliers mustalso abide by the principles in the dentsu Global Data Protection Principles, available at
Dentsu Group Global Data Protection Principles (Japanese, English）.
8.

Environment

Dentsu has committed to reaching net zero emissions by 2040 and is dedicated toimplementing and maintaining environmentally friendly business practices. Dentsu’scommitments are available for reference at Dentsu Group Environmental Policy (Japanese,English).
Dentsu expects its Suppliers to support dentsu’s commitment by:••••disclosing/working towards disclosing scope 1, 2 and 3 greenhouse gas emissions andbroader Environmental, Social and Governance (ESG) performance on dentsu request;
evaluating the environmental impact of its products and/or services and providing
reports at dentsu’s request;
regularly assessing its environmental risks and opportunities in relation to its operations
and managing those risks accordingly;
continuously improving its environmental performance and taking action to reduce its
carbon footprint;

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••

9.

ensuring compliance, as a minimum, with all legislation related to the environment
including climate-related disclosures and transition plans, where applicable to theirsector; andworking with dentsu to help reduce its wider impacts on nature (including carbon
emissions, water and energy consumption, land degradation, biodiversity loss,
pollution, and operational waste).
Conflicts of interest

Suppliers must ensure they avoid the appearance of, or actual conflicts of interest in its workwith dentsu. Suppliers must disclose to dentsu any actual or potential conflict of interest assoon as they are identified. Disclosures must be made to Speak up @ dentsu (dentsu Japan,International Markets), in addition,compliance@dentsu.com is available at InternationalMarkets.
A conflict of interest arises when an individual has a private and/or personal interest which
could appear to influence their decisions in conflict with their duties to dentsu and/or to theSupplier. Examples include a relationship by blood, marriage, or other personal partnership, abusiness partnership or investment.
10.

Reporting concerns

Suppliers must raise any actual or potential concerns or suspicions of wrongdoing related totheir engagement or relationship with dentsu, including any breaches of the Supplier Code,using the Speak Up @ dentsu portal and hotline that allows anonymous reporting available atSpeak Up @ dentsu (dentsu Japan, International Markets.
The portal and hotline are free to use, confidential and available 24 hours a day, 7 days a week.
The individual contacting Speak Up @ dentsu should state that the concern relates to dentsu.
Speak Up @ dentsu can be contacted by calling the toll-free number for the related country. A
list is available at Speak Up @ dentsu (dentsu Japan, International Markets). In addition,
concerned parties can also contact Speak Up @ dentsu via email at speakup@dentsu.com inInternational Markets. Details of this portal and hotline should be made available within thesupplier’s organisation and to any employees, contractors and sub-contractors working on thesupplier’s behalf for dentsu.
Version 1.0
Issued on 23 July, 2024

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