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Grayling Communications Limited is registered in England Registration Number 3140273
Registered office is 26 Southampton Buildings, London WC2A 1AN
Ethical Trading Policy
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
to growing our business and delivering shareholder value while maintaining an uncompromising stance
unethical practices, products, organizations and regimes.
The guiding principles of the policy apply to all Grayling companies in every international market
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
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
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.
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
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
own ethical position, it will be referred to our Global Ethical Policy Group for review and
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
industry or a region of the world that has been linked to slavery or forced labour, we seek
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
Clients - sovereign and political
Grayling will not work for governments of countries that are not members of the UN, EU, NATO or
We will not work with governments of countries where there are sanctions applied by resolution
United Nations or British Commonwealth, or where such a state does not enjoy normal diplomatic
with the international community.
We will not undertake proactive PR campaigns on behalf of political parties or individual
but from time to time we do undertake media training where we neither influence nor advise on
campaigns. This policy applies to all governments, or heads of state, of sovereign countries. It
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
record of human rights or civil liberties, we will refer the matter to Grayling’s Global Ethical
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:
Sovereign wealth funds
Health and wellbeing
Grayling and its parent company Huntsworth plc are head-quartered and registered in the United
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
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
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
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
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
and working practices.
We fully support and comply with all points covered in the Universal Declaration of Human
We fully support and comply with all guidelines laid out in the Fundamental International Labour
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
“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,
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
their own name and clearly point it out (EG Disclosure: I work with xxx brand). On a microblog
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
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
and / or recognised public relations and communications trade associations.
Statement - Slavery and Human Trafficking
Slavery and Human Trafficking Statement
Grayling is committed to providing its workers with safe, legal employment in a stimulating and
rewarding environment. There is no forced, bonded or involuntary labour within our workforce. We
comply fully with the UK Modern Slavery Act 2015 and all other legislation and guidelines designed
to uphold an individual's human rights and employment rights; this includes compliance with the
Universal Declaration of Human Rights and the practices laid down in the Fundamental International
Labour Organisation Conventions.
Our approach to compliance with the UK Modern Slavery Act 2015 is outlined in our Ethical Trading
Policy and various HR policies that govern recruitment, equal opportunities and diversity in our
workplace. All of these policies are reviewed regularly - and at least annually - to ensure that
they are fit for purpose and stay abreast of any changes in national or international legislation.
Staff are made aware of these policies - with training provided where necessary - during their
induction shortly after joining Grayling and all policies are available for staff to review through
shared intranet system.
As a communications consultancy, we do not have an extensive supply chain. However, we recognise
is vital that our partners, suppliers and clients uphold the same commitment to compliance with all
regulations around human and employment rights. We have a zero tolerance policy for any company that
found to condone, support or operate labour practices that breach an individual's rights and will
working with any organisation that cannot fulfil every aspect of our Ethical Trading Policy. Before
accepting a new client account, or entering into an agreement with partners or suppliers, we
that organisation's own labour policies and seek information on the steps that are in place to
any breaches of employment rights that may exist within their supply chains.
In accordance with the terms of the UK Modern Slavery Act 2015, we will publish an annual Slavery
Human Trafficking statement.
We will not collect any personally identifiable information about individuals, except as set out
in the Cookies section below or where it is specifically and knowingly provided by them.
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