Human Rights

Our commitment

To demonstrate dentsu’s corporate value to clients, employees, partners, and society, it is essential to uphold a strong commitment to human rights and comply rigorously with all relevant laws and regulations. These principles are also vital to our sustained success, as they help reduce operational disruptions and mitigate risks that could impair the Group’s reputation or valuation.

Governance

The respect for human rights underpins our purpose, vision, and value creation towards the realization of the society we aspire to create. Our Global Chief Governance Officer (GCGO) of Dentsu Group Inc. oversees efforts to ensure compliance with human rights-related regulations, robust risk management, and the assurance of business continuity.

The practical management of human rights impacts is overseen by our Heads of Human Rights, who build the internal networks needed to identify and manage human rights risks and opportunities, collaborating closely with relevant departments. This includes a variety of training content ranging from online sessions and function/practice-specific workshops to internal consultations.

Human rights are a standing agenda item at the Executive-level Group Sustainability Committee, which meets four times a year. Through this, we ensure that the Group has the necessary systems in place to manage impacts across all regions where we operate.
Issues specific to Japan are covered by the Dentsu Group Human Rights Committee and the dentsu Japan Human Rights Education Conference. (For details on specific initiatives, please see here.)

Human rights considerations are also represented at functional working groups including the Legal & Compliance Sustainability Working Group, the Sustainable Procurement Working Group and the Policy Working Group

Policies

“We honor internationally recognized principles of human rights. Abuses that contravene those rights will not be tolerated within our business or those of our business partners.” - Dentsu Group Code of Conduct.

Our Code of Conduct, Supplier Code of Conduct and standalone Human Rights Policy set out our commitment to honor all internationally recognized frameworks and principles of human rights, and our expectations toward all employees and suppliers.

Our Human Rights Policy was developed through cross-functional collaboration and external expert stakeholder consultation and has been approved by the Group Management Board. It is reviewed periodically to reflect operational changes, and compliance is tracked.

The policy outlines our commitments to mitigate our most salient human rights impacts – as identified by our Human Rights Saliency Assessment. (See Impacts and Risks for further information) and is complemented by detailed standalone policies for specific human rights impacts including our Human Resources Policy, Supplier Code of Conduct, Global Data Protection Principles, and Physical Security Policy.

The Human Rights Policy is communicated internally, including through an online training video, and is publicly available here.

All employees, suppliers and external stakeholders are encouraged to raise any human rights concerns through our externally operated, free, anonymous, and confidential Speak Up @dentsu portal.

Impacts and risks

We proactively identify and track global and market-level risks relating to human rights, including:

  • real-time SMS alerts for societal, environmental, and health and safety-related events;
  • bi-annual assessments of market risk profiles using open source data;
  • our annual employee engagement survey.

We have a dedicated resilience program that supports the physical security and wellbeing of our employees when operating in or travelling to conflict and natural disaster affected geographies.

We extend our risk screening to our Global Functions suppliers, assessing their risk profiles based on location, product category and questionnaire response.

We are committed to engaging with stakeholders to identify and verify our salient risks, including engagement with external human rights experts. We also conduct regular surveys to collect information on employee and consumer concerns.

To complement our ongoing risk screening, we appointed an external expert agency In 2024 to conduct a Group-wide Human Rights Saliency Assessment, identifying our salient human rights risks. This included interviews with internal and external stakeholders and incorporated feedback from affected stakeholder engagement through employee and consumer survey results. The assessment covered all aspects of our group-wide operations, including our supply chain.

Our most salient human rights issues are:

Salient issueCommitment
Equality and non-discrimination
  • We do not discriminate against any person on the basis of race, religion, nationality, ethnic or social origin, gender, gender identity, sexual orientation, age, pregnancy, neuro-diversity, differing physical or mental abilities, or any other characteristic protected by applicable law.
  • We uphold the principles of equal opportunity and non-discrimination in all aspects of our operations both in our workplace and in the marketplace.
Freedom of Thought, Opinion, Religion and Belief, and Freedom of Expression and Access to Information
  • We are committed to upholding the principles of Freedom of Thought, Opinion, Religion and Belief, and Freedom of Expression and Access to Information, recognising that these are essential to fostering creativity, innovation, and progress.
  • We strive to ensure that the creative and placement of our clients' adverts are not in contradiction with any applicable laws or regulations. 
Labor rights and harassment
  • We adhere to international labor standards and local regulations for all employees, contingent workers, visitors, clients, customers, and suppliers and in some circumstances, job applicants, candidates, and ex-employees at dentsu and its associated companies.
  • We do not tolerate bullying, discrimination, harassment, and victimization (i.e., retaliation) in the workplace, and provide anonymous channels for reporting and addressing concerns.
  • We have a zero-tolerance approach to all forms of slavery and a commitment to comply with applicable employment and human rights legislation, including relevant child labor laws. We require the same from our partners.
  • We respect the right of all workers to form and join a trade union of their choice or bargain collectively without fear of intimidation or reprisal, in accordance with national law.
  • In conflict-affected areas, where additional challenges may arise, we will take extra precautions to ensure the safety and security of our employees, working closely with local authorities and stakeholders to mitigate risks and uphold human rights.
Privacy and data security
  • We implement appropriate governance and assurance measures to ensure compliance with our data protection obligations. Our approach and commitment to this is enshrined in our Data Protection Principles.
  • We see data protection as a fundamental human right and strive to treat people and their personal data with care and respect so we can be a force for good for the organizations and partners with which we work and the communities in which live.
  • We are committed to transparency in our handling and processing of personal data at all times in accordance with applicable privacy and data protection laws.
Child Rights
  • We acknowledge the special protections afforded to children under international human rights law and commit to respecting and promoting the rights of children in all aspects of our work.
  • We adhere to laws and regulations governing the protection of children’s privacy and ensuring that any data collected from or about children is handled fairly and responsibly.
Right to a healthy environment
  • We identify and manage our environmental impacts to drive efficiencies, a healthy environment and long-term compliance with applicable environmental laws and regulations.

Risk Mitigation and Due Diligence

We conduct human rights due diligence throughout our operations and supply chain to identify, prevent, and mitigate risks and reduce their potential impact. Our approach is aligned with the United Nations Guiding Principles on Business and Human Rights and includes risk assessments, policy commitments (including our Human Rights Policy as well as standalone policies for specific human rights impacts), governance, executive sponsorship, training, and internal controls to monitor and track compliance.

  • Assess
  • Commit
  • Act
  • Embed
  • Track
  • Communicate

Our Heads of Human Rights work closely with our Global Functions – including Human Resources, Legal & Compliance, Procurement, Comms– and Practices teams to embed human rights considerations into existing management approaches and policies for each of our salient risks.

For example:

Privacy and data security
Our Global Data Protection Principles guide our understanding of what being a force for good means in the context of personal data processing - regardless of where in the world we may operate. These principles underpin the policies, standards, and behaviors that govern how we collect, use, and work with personal data across our business worldwide. They apply to both the personal data that we use to run our own business, such as employee data, as well as the data we process for our clients when delivering commercial services.

Compliance with our policies is tracked and monitored through our Internal Controls Framework.

Grievance and remediation

We encourage all employees and external stakeholders to raise any human rights concerns. We provide a variety of channels for employees to raise concerns and grievances including our Speak Up @dentsu portal, which is externally operated, free, anonymous and confidential, and available in all appropriate languages.

Our Supplier Code of Conduct requires suppliers to raise any actual or potential concerns or suspicions of wrongdoing related to their engagement or relationship with dentsu, including any breaches of the Supplier Code of Conduct, using the Speak Up @dentsu portal.

We have clear, documented processes and procedures to manage all workplace matters including employee grievances and concerns, and unacceptable behavior or misconduct. For example, in the case of workplace harassment and bullying, our markets follow the principles set out in our Human Resources Policy (EMEA, AMER and APAC) and the Declaration on Elimination and Prevention of Harassment (Japan), which set out definitions and processes for employees to raise concerns and how dentsu will address those concerns. The Human Resources Policy is supplemented by specific processes for individual markets which are outlined in the Employee Handbook.

We undertake thorough investigations into concerns raised, and where they are substantiated, we take appropriate remedial and corrective actions.

Employees and contingent workers receive annual training on our Code of Conduct, including information on using Speak Up @dentsu. Training on specific human rights risks such as Data Protection & Privacy, Ethics & Compliance, Generative AI use , and Harassment Prevention is also required annually.

Incidents

Since 2023, serious allegations of human rights abuses were recognized in the media and entertainment industry in Japan with which we engage. We are closely monitoring the status of the measures they are taking to rectify the issue, and are increasing our due diligence with this, in-line with our Code of Conduct, Supplier Code of Conduct, and Human Rights Policy.

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