What is the issue?
The impact of the work we do for clients is our most important sustainability issue. As trusted advisors to leading brands around the world, our companies have an opportunity to help clients understand what sustainability means for their business and to integrate social and environmental values into their brands, products and services. By developing our own sustainability expertise, and using this for the benefit of our clients, we can have a positive impact beyond our own operations, while generating revenue for our business.
At the same time, marketing work can raise ethical issues that we must manage carefully – from debates on taste and decency in advertising, to the risk that one of our companies could undertake commissions for clients implicated in unethical practices. As our digital and marketing research businesses continue to grow we must also implement robust privacy and data security standards to protect consumer and client data.
We are a truly global company and we value the creativity that comes from our many unique and different operating brands, each with their own culture. However, there is a need to ensure that we implement consistent standards across our many locations, even where local cultures and regulations differ.
WPP is a decentralised group, and our companies make their own decisions on the campaigns they undertake and the clients they work with. At a parent company level, we need to create the right framework so that the decisions our companies make reflect our Group values.
How we manage
The WPP Code of Conduct and Group Sustainability Policy help our people in dealing with a wide range of ethical, social and environmental subjects. They apply to all employees in all locations and are available on our website and intranet. Both are regularly updated.
These policies are implemented by our companies at a local level, with mandatory ethics and anti-bribery and corruption training for all employees. All WPP companies handle data that relates to their business, employees, clients and, in some cases, consumers. WPP is increasing its focus on how this data is collected, used and stored. All companies must comply with WPP data and security policies, and WPP’s Data Code of Conduct. Our IT security (ITS) audit team monitors compliance.
Our deputy general counsel, litigation and compliance, oversees our approach to ethics and compliance, and provides support and guidance to our companies. She reports to our Group chief counsel and director of Internal Audit. Companies implement additional policies and procedures as needed, depending on their business area.
Attitudes to subjects such as taste and decency evolve, and new issues can arise as technology develops. Our companies participate in industry groups and help to develop and evolve codes of practice for the marketing industry. 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.
Integrating sustainability into marketing campaigns
Many leading companies are already responding to the impact of sustainability issues such as climate change, water scarcity, poverty and inequality by improving the social and environmental performance of their products and services and engaging their customers and stakeholders on sustainability.
Our companies work with clients on these issues, and can play a role in helping businesses and governments to encourage and enable more sustainable patterns of consumption. Examples include:
- Research and insight: Helping clients to understand changing attitudes to sustainability issues and testing the impact of sustainability strategy and communications approaches.
- Branding and strategy: Our companies work with clients to embed social and environmental values into brands and business strategy, and to foster sustainable innovation.
- Consumer communications: Our advertising, digital and direct communications companies help clients communicate credibly with consumers and customers on sustainability and generate sales of sustainable products.
- Employee communications: Engaging employees on social and environmental issues and enabling clients to embed sustainability into their businesses.
- Stakeholder communications: Our public relations and public affairs companies help clients to communicate with regulators, the media, NGOs and the public on sustainability issues.
Our companies... can play a role in helping businesses and governments to encourage and enable more sustainable patterns of consumption
Sustainability expertise is increasingly integrated across our companies’ client teams and in addition many of our companies have established specialist sustainability offerings. These include Burson-Marsteller’s Global Corporate Responsibility Practice, Hill+Knowlton Strategies’ CR + Sustainability Communications, J. Walter Thompson Ethos, OgilvyChange, OgilvyEarth, P&G’s S-Team and PSB Green. In 2014, Young & Rubicam Group companies established INSPIRE, a multi-agency, cross-discipline service helping brands to understand the social responsibility landscape and create communications, marketing campaigns and partnerships to communicate their sustainability stories credibly.
At the parent company level we support the development of sustainability expertise and encourage collaboration between our companies. This includes providing access to background briefings on a wide range of sustainability topics via the Group intranet and publishing our Sustainability Navigator, a directory of sustainability expertise within WPP that enables collaboration across our companies. We help our companies respond to the growing number of client tender processes and supplier programs which include sustainability requirements.
We also work with brands, campaign groups and governments on social marketing campaigns, using the influence of marketing to help raise public awareness or bring about behaviour change in areas like health, safety and the environment. We have several companies with specialist social marketing units, such as Ogilvy Outreach, J. Walter Thompson Ethos, Thompson Social and TNS Political and Social.
Effective communications play a key role in helping governments to tackle major issues such as public health, to engage with citizens and to deliver services to growing populations. Many of the social marketing campaigns we undertake are for government clients. WPP companies work for the public sector in more than 60 countries and we have established a global Government & Public Sector Practice to drive excellence in public sector communications and help governments better understand and engage citizens.
Head of WPP’s Government & Public Sector Practice
“Marketing communications can change the world for the better. Our government clients need the best communications services to help bring about behaviour change, whether that’s communicating about how people need to access public services digitally or getting people in remote areas of Africa to use their malaria nets. The new WPP Government and Public Sector Practice will make it easier for them to access our expertise and to measure, monitor and evaluate their impact”
We are also establishing partnerships with academic institutions to develop and deliver executive education on communications for current and future policy makers. Leaders from WPP companies are directly involved in delivering training which is designed to raise awareness of the role and potential impact of communications in public policy delivery and behaviour change. Current partnerships include, for example, a teaching collaboration in Singapore with the Lee Kuan Yew School and a partnership with the Blavatnik School of Government at the University of Oxford.
Responsible brands – recent client work
We work with a growing number of clients on campaigns that are designed to engage customers and citizens on sustainability issues. These are just a few examples from 2014.
Engaging consumers and citizens on sustainability
Supporting women’s empowerment
Promoting healthier behaviour
Highlighting social issues
Embedding an ethical framework
The WPP Code of Conduct establishes the values and ethical standards that all our companies must implement. It is supported by our Group Sustainability Policy and detailed policies on anti-bribery and corruption, gifts and entertainment and the appointment of third-party advisors. Senior executives in all our companies and all our business partners and suppliers are asked to sign a copy of the WPP Code of Business Conduct each year to confirm they will abide by its principles.
Our companies must all achieve standards that are consistent with those in our Code of Conduct, but have the freedom to develop their own policies and procedures, suited to their business and operating environment.
Business ethics training and engagement
Employees are required to complete both our ethics training, ‘How we behave’, which covers topics such as diversity, privacy, responsibility to stakeholders, and avoiding misleading work and our online training on anti-bribery and corruption, which 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 two to three years and employees are required to repeat the training following each update. The training is compulsory for all employees (not including associates) and over 160,000 employees completed it during 2013–2014. This figure is higher than our current number of employees (not including associates) as it includes those who have left the business during the last two years.
employees completed our ethics training during 2013-2014
Employees can report any concerns or suspected cases of misconduct in confidence through our third-party managed Right to Speak facility, overseen by our internal audit department. This is publicised through induction packs, the Group intranet, the WPP Policy Book and our ethics training. There were 52 calls made via Right to Speak during 2014, all of which were followed up.
Associates and partners
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. We communicate our expectations to associates and affiliates and we are in the process of extending our ethics training and anti-bribery and corruption training to employees of WPP’s associate and affiliate companies. Online training will be made available to associates and affiliates in 2015.
Ethical decisions in our work
The work we do and the clients we work for can raise ethical issues. Examples include work for governments or clients in sensitive countries or sectors, and marketing for sensitive or controversial products. We need to help our people make decisions about new commissions that reflect our standards, and to avoid ethical risks to WPP and our clients. We will turn down work which presents an unacceptable ethical risk to WPP or our clients.
WPP companies have a review and referral process for work that may present an ethical risk. Before accepting potentially sensitive work, employees 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. Employees are trained on this referral process during our ethics training.
Companies also have their own procedures, including 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 that are highly regulated.
Our ethics training includes scenarios to help employees identify ethical risks associated with client work, and raises awareness about referral procedures. We have also undertaken face-to-face training on issues such as intellectual property and copy clearance with some of our companies. Depending on scope, internal audits may incorporate a review of the consideration given by management to possible impacts on the Group’s reputation prior to accepting new clients.
We have a Group-level committee that meets regularly to discuss cases of concern, potential compliance issues and new risk areas. Committee members include the Group chief counsel, deputy general counsel, litigation and compliance, Group finance director, the head of talent and the head of sustainability. The committee also reviews potential client-related risks such as bribery and corruption, data privacy and competition rules. The committee met on three occasions in 2014.
A very small number of the campaigns we produce give rise to complaints, some of which are upheld by authorities. We monitor complaints and take action where needed to prevent a recurrence.
Public affairs and lobbying
We undertake public policy work for clients, including direct lobbying of public officials and influencing public opinion. The majority of our public affairs work is undertaken for clients in the US, although many of our clients are multinational companies.
Our public affairs companies include: Burson-Marsteller, and its affiliates: Prime Policy Group, Direct Impact and Penn Schoen Berland; Glover Park Group; Hill+Knowlton Strategies, and its affiliates: Dewey Square Group and Wexler & Walker Public Policy Associates; OGR; QGA.
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 maximum transparency on client representation and require lobby firms to register the names of clients on whose behalf they contact legislators or executive branch personnel. 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.
Compliance with marketing standards
We set great store by maintaining high standards of integrity and honesty. Our companies take special care in marketing to children, and when producing work for products or sectors that are potentially sensitive.
Privacy and data security
Consumer data is increasingly used to shape and inform marketing campaigns, enabling companies to create highly-tailored marketing, to engage more effectively with consumers and to accurately measure the impact of marketing. However, alongside this opportunity we have a responsibility to protect consumer privacy and give people control over if and how their data is collected and used.
of WPP companies have taken mitigation measures which match or exceed their level of privacy risk
At WPP, data is central to our business as our companies collect, store and use consumer data on behalf of clients. We take action at a Group and operating company level to make sure that consumer privacy is protected and that we engage with consumers, regulators, clients and industry to improve privacy practices.
We work closely with our clients on these issues and with peer companies and industry bodies such as the Advertising Association, W3C Tracking Protection Working Group and the Interactive Advertising Bureau on privacy-related issues.
Policies and training
All WPP companies must implement the WPP Data Code of Conduct, launched in 2013, which provides a clear framework for implementing privacy best practice and our global IT security, privacy and social media policies.
of WPP companies have a dedicated privacy lead
We bring our Code and policies to life for employees through Group-wide ethics training, which features four privacy-related scenarios. We also run more detailed, bespoke training sessions on specific topics. In 2014, this included sessions on social media, privacy, data security and supplier and client contracts.
In 2014, we also developed and introduced the WPP Client Contract Toolkit, together with guidance on data privacy and security terms in contracts. This is designed to help WPP companies understand how privacy and data protection criteria should be integrated into client contracts.
We have a central team of legal, audit and compliance professionals who support WPP agencies on privacy, while our internal audit team reviews privacy risks and practices as part of its Group-wide audit program, focusing on different companies each year. Audits are conducted in line with our global IT security policy, and we use our data risk management tool, the WPP Data Health Checker, to help focus these reviews.
Performance in 2014
In 2014, we used our Data Health Checker to review privacy risks and practices in our businesses for the second year running. Our operating company chief information officers (CIOs) played a key role this year in the 2014 survey and we received responses from 91% of our businesses. 2014’s survey focused on practices governing the collection, storage and use of personal data and included a question on encryption of laptops.
The results showed us that 88% of the WPP companies involved have taken mitigation measures that match or exceed their level of privacy risk. On average, companies were found to have a risk score of 2.7 out of 5, with 5 being the highest level of risk, with the average score for mitigation measures at 3.4 out of 5 with 5 being the highest level of mitigation. Of those companies surveyed, 77% have a dedicated privacy lead and 45% of WPP companies have trained all of their employees on data privacy in addition to Group training.
We work with a number of suppliers who collect, manage and store consumer and client data on behalf of WPP companies and our clients. It is essential that all these suppliers have the right data security and privacy standards in place, to protect consumer privacy and to reduce legal and contractual risks to our companies and our clients. In 2014, we ran a pilot project with Sedex to gain a better understanding of sustainability and data security risks in our data supply chain.
Looking ahead to 2015
As we continue to embed privacy best practices across the Group, we will develop a ‘Safer data’ campaign in 2015, using humour to further engage employees on consumer privacy issues. We will also launch new training on online data security and privacy, making this compulsory for new joiners.
Chief operating officer, GroupM Interaction North America
The importance of trust in digital marketing
Behavioural advertising, the ability to collect and use data online, enables brands to deliver targeted and relevant advertising to users, and to connect with consumers in meaningful ways. But it only works if consumers trust marketers to protect their data and respect their privacy. This trust must be earned. Although the type of data media agencies collect and use is non-personal and is shared through anonymous cookies, this does not minimise the obligation to act responsibly and protect consumer privacy. Core to this is ensuring that consumers are comfortable with sharing data and understand how cookies work. Marketers have an obligation to be transparent with consumers about data use practices, and to give consumers control over whether and with whom they share data. Communicating the value consumers gain from sharing data is important.
GroupM and WPP have been a part of the team who pioneered and created the self-regulatory initiative AdChoices. AdChoices establishes principles for responsible privacy practices. Its icon informs users that data is being collected about their browsing behaviour and allows them to opt-out. The AdChoices icon now serves over 1 trillion impressions a month globally and has expanded from the US to Europe, Canada and Australia. We should remember that the digital landscape is still in its infancy. The acceleration of data sharing from mobile devices, the growth in location data and automotive data, and development of The Internet of Things, only makes these issues more complex and responsible privacy practice and trust more important.
GroupM Interaction North America develops the tools and processes for GroupM’s digital operations.