The Warner Bros. Discovery group (a group of companies directly or indirectly owned by Warner Bros. Discovery, Inc. (“WBD” or the “Company”)) was formed in April 2022, upon the acquisition of WarnerMedia, LLC by Discovery, Inc., two entities which were leading media and entertainment companies headquartered in the U.S. with businesses in television networks and film and operations in the United States and, through subsidiaries, internationally, including in the United Kingdom. For more information on the Company’s businesses and brands, please visit WBD’s website at https://wbd.com/our-brands/.
Throughout 2022, the Company worked to harmonize policies and procedures among its operating entities globally, including across its legacy UK subsidiaries.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes WBD’s group slavery and human trafficking statement for the financial year ended 31 December 2022. The WBD group entities with operations in the UK which meet the criteria set forth in the Act and covered by this statement are: (1) Cable News International Limited; (2) Discovery Communications Europe Limited; (3) Discovery Corporate Services Limited; (4) Dplay Entertainment Limited; (5) Rocksteady Studios Limited; (6) TT Games Limited; (7) TT Games Studios Limited; (8) Turner Broadcasting System Europe Limited; (9) Warner Bros. Entertainment UK Limited; (10) Warner Bros. Studios Leavesden Limited; (11) Warner Bros.
Productions Limited (12) Warner Bros. International Television Production Limited; (13) Warner Bros. Television Production UK Limited; (14) Warner Media International Limited; and (15) WBD Sports Events Limited (formerly known as Discovery Sports Events Limited). This statement was approved by the respective Boards of Directors of each of the foregoing WBD group companies.
The WBD Code of Ethics
WBD is committed to conducting its global business with high ethical and legal standards, including within its supply chain. That commitment begins with the WBD Code of Ethics (the “Code”), which is publicly available at https://ir.wbd.com/governance/ethics/default.aspx in various languages. The Code replaced legacy policies – specifically, the WarnerMedia, LLC Standards of Business Conduct and the Discovery Inc. Code of Ethics – which emphasized the same core ethical principles. The Code applies to all Company employees and serves as a model for comparable Codes that have been adopted by each of WBD’s businesses, including those outside the U.S. The Code stresses the importance of abiding by the law, acting with integrity, reporting concerns, being transparent in our business dealings, and promoting a safe and respectful workplace, including upholding human rights and being environmentally responsible.
Supply Chain and the WBD Business Partner Statement of Ethics
The Company’s supply chains include suppliers based in many countries providing a range of products and services. As a global media company, WBD’s core business is in the production and distribution of media content. The Company’s main supply chains include vendors of IT support, data centers, transmission and distribution partners, local production partners, software and technology contractors. Our content supply chains are diverse and include commissioned content created by production companies and finished content licensed from distribution and production companies. For that reason, our business and that of most of our suppliers involve operations in which the roles being performed are largely technical and/or professional, and the risk of modern slavery and human trafficking is low. Additionally, a smaller supply chain supports our licensing business, which makes our intellectual property available to select manufacturers for the creation of consumer-branded products. WBD has reviewed its supply chain to consider where there are areas of risk in relation to modern slavery.
In addition to the Code, WBD has adopted a Business Partner Statement of Ethics (the “Statement of Ethics”) which establishes expectations for our business partners’ and suppliers’ business operations as they relate to WBD and its businesses and reflects our commitment to conduct business in an ethical manner and in compliance with applicable laws and regulations. The Statement of Ethics is publicly available in multiple languages at https://ir.wbd.com/governance/ethics/default.aspx.
More specifically, the Statement of Ethics sets forth the Company’s expectations with respect to, among other areas, non-discrimination, a safe and healthy work environment that is free of harassment, respect for human rights, including prohibiting the use of any form of forced, bonded, or indentured labour, and environmental responsibility. WBD expects our business partners and suppliers to comply with the Statement of Ethics.
We strive to hold our employees and business partners, including suppliers, accountable for acting with ethical and legal standards of business integrity. To ensure that modern slavery is not occurring within our supply chains, we make reasonable efforts to learn our business partners’ reputation and work practices, including as they relate to legal compliance and respect for human rights. Contracts with suppliers are periodically reviewed to confirm that the Statement of Ethics is incorporated. WBD reserves the right to take any actions it deems appropriate to monitor and promote adherence to the Statement of Ethics and may discontinue relationships with suppliers and other business partners who fail to meet our high standards for ethical business conduct.
WBD understands that a key component of an effective compliance environment is employee training and education regarding the rules and policies that apply to their business activities, as well as WBD’s commitment to ethical business conduct. Employees receive training on the Code upon joining the Company, in addition to regular ethics and compliance training on laws that apply to our business activities. These training initiatives reinforce the Company’s commitment to compliance with laws and ethical behavior.
WBD believes in the value of collaborating and sharing information to improve responsible sourcing efforts across the globe. WBD’s businesses are members of industry working groups, such as the International Licensing Industry Merchandisers’ Association (LIMA).
Training
WBD understands that a key component of an effective compliance environment is employee training and education regarding the rules and policies that apply to their business activities, as well as WBD’s commitment to ethical business conduct. Employees receive training on the Code upon joining the Company, in addition to regular ethics and compliance training on laws that apply to our business activities. These training initiatives reinforce the Company’s commitment to compliance with laws and ethical behavior.
Reporting and Monitoring Misconduct
Employees are encouraged to report any misconduct or unethical behavior. The Company and its businesses provide multiple means of reporting concerns, including a Hotline monitored 24-7, which enables anonymous reporting where permitted by local law. Third parties also can report concerns, including through the Hotline (where permitted by local law) or via an online portal. These various means of reporting are an important mechanism for us to track the effectiveness of our modern slavery and human trafficking policies and they are listed in both the Code and the Statement of Ethics.
WBD is committed to acting ethically and with transparency in all our business relationships and to implementing and enforcing effective systems and controls to try to ensure that modern slavery and human trafficking is not taking place anywhere in our supply chains. We take a zero-tolerance approach to slavery and human trafficking. WBD and its businesses encourage anyone to report in good faith issues about potential ethical, legal, regulatory, slavery, human trafficking or human rights violations. The Company will investigate allegations and take appropriate remedial actions. In 2022, WBD did not identify any incidents of modern slavery or human trafficking in our businesses or supply chains. We are not aware of, nor do we have any information to suggest that any inappropriate labour conditions are present in our supply chains.