UK Modern Slavery Act Transparency Statement

This serves as APCO’s transparency statement under Section 54 of the UK’s Modern Slavery Act 2015 (the “Act”).

APCO’s commitment to a strong compliance culture is fundamental to its continued growth as an international strategic communications firm. You will find below details of our policies, procedures and practices aimed at eradicating slavery and human trafficking from our global services chain.

Corporate Structure and Businesses

APCO is a global strategic communications firm.

APCO operates in more than 30 countries across the world with over 500 employees.  It has significant offices in 4 key geographies – USA, Europe, Middle East, and Asia.

Anti-Trafficking/Slavery Policies

APCO’s Code of Conduct provides the foundation for our business culture and underscores our commitment to performance with integrity and respect for human rights. The Code of Conduct provides guidelines for employee conduct and affirms our commitment to uphold our core values, such as our commitment to our employees, standards for doing business, and our relationship with our communities. We embrace the Code of Conduct, every day and in every business dealing across the globe.

Our policy on Anti-Corruption includes our responsibility to follow all applicable laws as well as our own internal policies and to require any supplier or third party who works with APCO to comply with similar fundamental principles.

In addition, APCO requires the strict observance of all applicable labor and employment laws wherever APCO operates in the world; this includes supporting the prohibition of forced, compulsory and child labor.

Anti-Trafficking/Anti-Slavery Due-Diligence Processes

For certain business areas, APCO has established processes in place to vet potential and current suppliers for their involvement in modern slavery and human trafficking; such processes include questionnaires and on-site audits for those suppliers deemed to be in the medium and high risk categories.  If we discover evidence of slavery or human trafficking with one of our suppliers through this process, we will refrain from doing business with this supplier and will report such conduct to the relevant authorities, as appropriate.

Anti-Trafficking/Anti-Slavery Training

All APCO employees receive regular training on the Code of Conduct and Anti-Corruption Policy and other related policies, including on fair employment practices. Employees are encouraged to seek compliance guidance from, and to report compliance concerns to, their managers, the Legal department, Human Resources and APCO’s Compliance Helpline. Trained personnel investigate all incidents in a timely manner. All credible reports of suspected misconduct are investigated. Confirmed violations are addressed with corrective actions, and may include employee discipline or dismissal.

Updated September 2016