Ethical Trading Policy


Our Approach

At Grayling, we take our responsibilities as a global corporate citizen very seriously; we are fully committed to operating ethically and demonstrating good stewardship throughout all of our business operations across the world. While we are a commercial organisation, we recognize the need to always carefully balance our business goals with our moral and ethical obligations. As such, we are dedicated to growing our business and delivering shareholder value while maintaining an uncompromising stance on unethical practices, products, organizations and regimes.

The guiding principles of the policy apply to all Grayling companies in every international market in which we are active. Where we have established formal affiliate relationships with other agencies to deliver work under a Grayling contract, our affiliate partners operate by the same guidelines.

Grayling’s Global Ethical Policy Group

This comprises a small number of senior level board directors drawn from across our business. All of our international regions are represented and the group is chaired by Grayling’s Global Leadership Team. Grayling’s Global Ethical Policy Group is responsible for the creation, review and implementation of our Ethical Trading Policy. It reviews any issues raised by our consultants from around the Grayling network. Such issues may include, but are not limited to, potential clients (current or new) whose operations cause some level of concern against our own ethical stance.

Clients - products and services

Many companies have diverse portfolios of products, services and industry sectors they serve. Therefore, it is difficult to develop a definitive list of commercial organisations that Grayling wouldn’t work with. However, we will not accept any assignments that would require us to:

  • promote tobacco smoking or support any operations of tobacco companies;
  • encourage activities deemed to be illegal in the countries in which the campaigns are to be delivered;
  • encourage excessive consumption of, reliance upon or addiction to: alcohol; food; non- prescription medication; gambling;
  • promote alcohol to those below the legal age limit defined in each territory / country / state
  • support an organization which is actively selling arms to governments or other parties where a military or civil conflict exists that contravenes UN resolutions and / or sanctions.

We will judge every prospective client on an individual basis and will not accept a contract or fees from an organization that is obviously reliant on any of the activities outlined. If a client’s operations are not covered by this scope, but we remain concerned that its activities may compromise our own ethical position, it will be referred to our Global Ethical Policy Group for review and decision.

Clients - labour standards

We have a zero tolerance policy for any company that is found to condone, support or operate labour practices that breach an individual’s human rights and employment rights. We will only work with companies that can demonstrate that they comply fully with all national and international labour legislation, including the UK Modern Slavery Act 2015. If a client or prospective client is active in an industry or a region of the world that has been linked to slavery or forced labour, we seek information on the steps that the organisation is taking to address any breaches of human rights or employment rights that may exist within its own supply chains.

We will maintain the highest levels of transparency around our client relationships. We will not comply with any client request for us to distort the truth about the client’s business activities or practices.

Clients - sovereign and political

Grayling will not work for governments of countries that are not members of the UN, EU, NATO or British Commonwealth.

  • We will not work with governments of countries where there are sanctions applied by resolution of the United Nations or British Commonwealth, or where such a state does not enjoy normal diplomatic relations with the international community.
  • We will not undertake proactive PR campaigns on behalf of political parties or individual candidates, but from time to time we do undertake media training where we neither influence nor advise on content or campaigns. This policy applies to all governments, or heads of state, of sovereign countries. It also applies to organizations that are 100% funded by sovereign states.
  • If countries or governments fulfil all of the criteria above, but there is still some concern over the record of human rights or civil liberties, we will refer the matter to Grayling’s Global Ethical Policy Group for review and decision.

If a prospective sovereign state client fulfils all of the criteria above, we will work with their agencies and charitable trusts for remits including:

  • Tourism
  • Inward investment
  • Sovereign wealth funds
  • Privatisation
  • Health and wellbeing
  • Education
  • Environmental projects
  • Cultural projects

Grayling and its parent company Huntsworth plc are head-quartered and registered in the United Kingdom. We maintain a close working relationship with the UK Foreign & Commonwealth Office and we will seek their guidance before embarking on any work that will directly or indirectly support a country or government. Other international security and rating agencies may also be consulted to obtain risk analysis and advice.

Grayling’s environmental and sustainability standards

We have genuine expertise in environmental and sustainability communications campaigns around the world. As such, Grayling’s specialist sustainability team possesses a deep knowledge of best practice in environmental stewardship. This has contributed towards the development of Grayling’s own environmental policy which is adopted throughout our network.

The basic principles include, but are not limited to commitments to:

  • Minimize waste by ensuring sound procurement and re-use strategies
  • Reduce energy usage wherever possible
  • Prevent pollution and conserve natural resources wherever possible
  • Adhere to the standard environmental policies of each country we operate in

We will not accept a contract or fees from an organization that we know to have knowingly/deliberately contravened environmental legislation in any of the countries in which they operate.

Grayling’s employment policy and working practices

Grayling’s resources are our greatest asset. We believe it is our responsibility to offer a stimulating and rewarding environment in which to work and learn. This policy is supplemented by further country-specific policies governing equal opportunities, discriminatory behaviour, health and safety, and working practices.

  • We fully support and comply with all points covered in the Universal Declaration of Human Rights
  • We fully support and comply with all guidelines laid out in the Fundamental International Labour Organization Conventions
  • We fully support and comply with all the terms covered by the UK Modern Slavery Act (2015)
  • We look towards our clients, suppliers and partners to operate in accordance with every aspect of our Ethical Trading Policy. We will cease working with any partner or supplier who cannot fulfil every aspect of this policy.
  • When working with suppliers and subcontractors our standard payment terms are 60 days but we are willing to negotiate.

Grayling’s delivery of communications services

Grayling is committed to ethical communications, providing our clients with highest professional standards based on transparency and best practice. Consequently we do not engage with any of the following practices:

  • “Astroturfing”: the artificial creation of grassroots buzz for a product, service or political viewpoint. This includes adopting automated astroturfing, for example online zombie services to increase social media buzz, generate spam content or increase page hits, video views, clicks, etc.
  • The use of social media for covert marketing or public relations purposes. If an employee or contractor has a vested interest in something they are discussing or promoting, they must always use their own name and clearly point it out (EG Disclosure: I work with xxx brand). On a microblog such as Twitter, this is generally done by adding a (disc: client) or (cl) when space is limited.
  • Offering payments for coverage to a journalist, publication, stakeholder, blogger or advocate without full disclosure, (for example, flagging as advertorial or sponsored).
  • Any such practices not detailed here that are deemed to be illegal in the countries in which a campaign is to be delivered and / or inconsistent with best industry practice as described by the ICCO and / or recognised public relations and communications trade associations.