Associated Press Television News Limited Slavery Statement

INTRODUCTION AND POLICY STATEMENT

Associated Press Television News Limited is the UK subsidiary of The Associated Press, which has its head office in New York (collectively “AP”). Founded in 1846, today AP is the largest and most trusted source of independent news in the world and is focused on finding, reporting and distributing news on a global scale.

As one of the largest and most trusted sources of independent newsgathering, AP is committed to maintaining the highest standards of objective and accurate journalism. Equally important is our commitment to ensuring equality directly throughout our organization, and through our mission to provide fast, focused and reliable news. AP recognizes the legal and moral importance of combating slavery in all its forms across the globe, and is fully committed to ensuring that our operations are run responsibly. Modern slavery is not only a serious crime, but also violates fundamental human rights in the name of personal and/or commercial gain. This translates into a zero-tolerance approach to any form of slavery both within the AP structure itself and through all secondary means of news collation.

This is the third Modern Slavery Statement of Associated Press Television News Limited published in accordance with the Modern Slavery Act 2015. This updated statement includes the steps AP has taken in the last year to counter the risk of modern slavery in its organization and supply chains and sets out the steps AP will be taking in the next 12 to 18 months to continue to remain compliant.

ABOUT THE AP

To provide AP Services to its customers, AP works alongside a great number of third parties to ensure the news we report is accurate and unbiased. Often, AP must report from the most inaccessible and hostile places on earth in order to bring current events to the attention of the world.

To facilitate this, AP has a network of staff in more than 280 locations with a variety of employee types, from full-time office-based staff to freelancers based where news stories are breaking around the world. To be able to report news on such an international scale, AP's workforce is inherently dynamic, with ever­ changing suppliers and partners. The result of our structure means that an estimated half of the world's population see AP content on any given day.

RISKS IDENTIFIED AND STEPS TAKEN TO DATE

 AP continues to analyse its business practices to establish which areas of the business itself and supply chains represent a risk of modern slavery and where the AP's focus should be. Based on this analysis, AP continues to actively:

• Review terms within our supply chain contracts
• Review internal policies in place
• Review and amend language added to our agreements
• Conduct regular compliance training for all employees and senior management

 AP SUPPLY CHAINS

 Owing to its global presence, AP is aware that there are places from which we report that may not take the same stance against slavery. To combat this, AP ensures that where possible, we know the third parties we work with, creating an open and honest workplace with similar values and a mutual respect for human rights generally and specifically, the anti-slavery values we hold as a company. Where news breaks, AP must react quickly and will often use information from ad hoc providers. In situations where we do not have an established relationship with the provider, AP will always use its best efforts to ensure that the information provided is done so freely, without duress and in compliance with the Modern Slavery Act 2015. AP, like all worldwide news organisations, must do its best to strike a delicate balance between the fast and factual reporting of world events and the protection of individual freedoms and rights, both inside and outside of the AP structure. Where possible, we avoid using anonymous sources so as to minimize the risk of engaging with questionable third parties, preferring to be able to research the parties in question prior to usage.

With such a wide ranging and dynamic business structure covering the worldwide gathering, production and distribution of news; AP's supply chains are diverse and far reaching. However, we maintain stringent source checks even where the source supply chain becomes more complex. Internally, we are constantly evaluating the source of our content and how it is collected and communicated to ensure that the prevention of forced labour is at the forefront of our business structures and our ethos more generally.

AP COMPLIANCE POLICIES AND REPORTING MISCONDUCT

AP employees are encouraged to report any misconduct or unethical behaviour.

The AP Code of Business Conduct and Ethics reflects both AP's and its subsidiaries' commitment to conduct business in accordance with relevant legal and ethical standards. Where employees have questions about the code or have become aware of a possible policy violation, they are encouraged to immediately report their concerns.

Further, AP operates a confidential 'Integrity Hotline', which is accessible to employees, members, vendors and customers as "a confidential means to report on suspected violations of company policy, law, and/or other potential improper business conduct."

FURTHER STEPS

AP fully understands and recognizes that a continual risk analysis is necessary to ensure that the AP's business operations and supply chains remain compliant with the Modern Slavery Act 2015. In the next 12 to 18 months AP will:

• Continue to review the policies in place within the organization, all contracts in place with suppliers of content and other services and all partner relationships in place throughout the world, to ensure AP remains fully complaint with the legislation and be able to highlight the areas where modern slavery could be a risk.
• Continue to build on the steps we have taken to date to highlight the issue of modern slavery and ensure all staff are aware.
• Develop further online sessions and FAQs available to all employees on the AP intranet site.
• Conduct additional compliance training.
• Review contractual clauses in all agreements with partners and suppliers to ensure additional obligations are in place with them.
• Continue to carry out thorough due diligence reports for new and renewing suppliers.

This statement has been approved by the Directors of Associated Press Television News Limited.

ASSOCIATED PRESS TELEVISION NEWS LTD
Date: September 2019