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Human Trafficking Statement for Fiscal Year 2016

The UK’s Modern Slavery Act recently came into effect with the goal of eliminating human trafficking worldwide. At Warner Music Group, we are both complying with this law and taking steps as a company to support this effort. WMG and its subsidiaries are implementing the following measures to support our zero tolerance policy for modern slavery and human trafficking anywhere in our supply chain, including our third party vendors.

 

Internal Accountability

 

Through the WMG Code of Conduct, as well as our Whistleblower and Anti-Corruption policies, we seek to promote honest and ethical conduct and support compliance with applicable laws and regulations wherever in the world our business is conducted. All employees and officers of WMG must sign up to the Code, acknowledge that they understand its contents, and agree to comply with its terms in both spirit and law.

 

Supply Chain Review

 

We source our goods from a diverse supply base and we have a zero tolerance policy for any suppliers who do not comply with all laws, including laws pertaining to trafficked, bonded, child, prison, indentured or forced labor. Wherever possible, we build long standing relationships with local suppliers and insist on visibility into their business standards.

 

During the past year, WMG reviewed its business and supply chains, focusing principally on areas of higher risk. Our review has identified no evidence of trafficked, bonded, child or forced labor within our supply chain.

 

We will continue to regularly review of our supply chain as part of our efforts to assess, monitor and reduce areas of potential risk in our supply chain, as well as provide safe whistle blowing mechanisms.

 

Further Steps

 

After a review of the measures we’ve taken this year to combat the risks of modern slavery and human trafficking in our supply chains, we intend to also take the following steps in 2017: 

 

- Ensure we include specific provisions in all our standard supply chain contracts requiring suppliers to comply with the Act and commit contractually, where appropriate, that neither they nor any other person in their supply chain uses trafficked, bonded, child or forced labor or has attempted to use trafficked, bonded, child or forced labor within their supply chain.

 

- Develop and implement a training program around the Act to ensure that employees responsible for engaging with suppliers understand the importance of ethical conduct, can identify any issues within the business and report concerns to senior management or through appropriate whistle blowing mechanisms; and

 

- Continue to undertake audits of existing and potential suppliers to ensure that, so far as possible, the supply chain is always operating ethically and consistent with the standards of WMG.

 

This Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes our human trafficking statement for the previous financial year (FY16).  The board of directors of Warner Music Group delegated approval of this statement on its behalf to the Chief Compliance Officer of WMG.  

 

Trent Tappe

SVP, Chief Corporate Governance & Securities Counsel and Chief Compliance Officer

Warner Music Group

 

March 31, 2017