Kantar Media Right to Speak Policy
Kantar Media is committed to:
- providing and maintaining a culture of open and accountable management
- conducting business ethically, honestly and within the spirit and letter of the law
- facilitating open and honest communications whereby all colleagues feel able to raise concerns about actual or potential violations of our internal policies, the law or our regulatory obligations, and trust that any reports raised will be considered and addressed without retaliation.
We want to behave with integrity and treat others with respect. During your work, you may be confronted with ethical concerns or dilemmas. We encourage you to raise any concerns you have about the way that Kantar Media operates and conducts its business, or about any suspected danger or wrongdoing. This keeps us all accountable and helps us continually improve our business and culture.
We understand that it takes courage to speak up, so therefore we are committed to providing you with an easy and safe way to raise your concerns. Speaking up is an essential part that enables us to protect our people, our company values, our stakeholders and society as a whole. No one should be alone when dealing with an ethical dilemma. In this document (our Right to Speak Policy) we clearly explain what your options are and how you can raise your concerns.
The legal systems of some countries may have different requirements and give individuals who report issues different protections than Kantar Media policy. In the event of a divergence between Kantar Media’s Right to Speak Policy and local law, local law will prevail. You can find a list of countries and the different protections offered here.
What’s included in this policy?
This Policy summarises:
- the kind of issues you should raise via our Right to Speak process
- how to make a report
- how reports will be treated by Kantar Media
Before we get into the details of the Policy, it’s useful to clarify what we mean by certain terms. In this Policy references to the following terms shall have the meanings set out below:
“Kantar Media” means each company in the Kantar Media group of companies.
“Report” means an oral or written disclosure of information or a reasonable suspicion, about an actual or potential breach, which has occurred or is very likely to occur. It also covers an attempt to conceal such breach.
“RTS” means Right to Speak.
Who does this policy apply to?
This Policy applies to:
- All prospective, current and former employees and other individuals working for or providing services to Kantar Media, such as our contingent workers and our casual workers, collectively known as our colleagues
- All our prospective, current and former interns, and work experience students
- All shareholders
- Board members (including non-executive directors)
- Employee, trade union or works council representatives who have advised or represented an individual making a report
- Any individual working under the supervision or control of our contractors, subcontractors or suppliers
- Any person assisting a reporter in the reporting process, and a colleague or relative (who may suffer retaliation)
- A legal entity owned or connected with a reporting person
For clarity, this Policy does not form part of any contract of employment or engagement and Kantar Media may withdraw or amend it at any time.
What kind of concerns can be raised via Right to Speak?
Right to Speak can be used to report any concerns you have about the way that Kantar Media operates and conducts its business, or about any suspected danger or wrongdoing. This includes any actual or suspected breach of the Kantar Media Policy Book, the law or our regulatory requirements. For example, this could include reports about any of the following, but please note that this is not an exhaustive list:
- Any breach of applicable law or our legal or regulatory obligations
- Criminal activity
- Conflicts of interest
- Misconduct or breach of Kantar Media policies
- Dangers to health and safety
- Damage to the environment
- A miscarriage of justice
- Financial fraud (including any type of fraud, any breach of the rules or regulations of the US
- Securities and Exchange Commission, and any US federal law relating to fraud against shareholders), theft, money laundering, terrorist financing or mismanagement
- Discrimination or harassment
- Corruption, bribery or tax evasion
- Unethical or inappropriate behaviour
- Protection of privacy and personal data,
- security of our networks and information systems, and any breach of our data protection and/or cyber securities policies and procedures
- The deliberate concealment of any of the above matters.
How do I report a concern?
You can raise a concern, provide feedback or ask your questions in a variety of ways. For many matters, it can be a good first step to talk to the person involved directly. Thus, our Right to Speak Policy and process should not entirely replace the direct dialogue that forms the foundation of our transparent company culture. However, we recognise that this is not always easy to do.
If this is not possible, or if you do not feel comfortable doing so, please turn to our Right to Speak channels as described below:
- Speak to your manager or your manager’s manager
- Speak to your local HR representative or email Compliance at km.compliance@kantar.com
- Raise your concern via SpeakUp
- SpeakUp is operated by an independent service provider and is available 24/7. It facilitates reports being made in a safe and confidential way.
- Via SpeakUp you can speak up or ask questions directly to the SpeakUp office where there are highly qualified specialists handling reports.
- You can raise your concern in your own language, via phone or online via our website.
- Qualified colleagues will handle your report internally.
- You can decide to remain anonymous.
In the annex ‘contact & useful links’, you will find all relevant practical details.
What information should be provided when raising a concern?
When making the report you should expect to provide the following information:
- Your relationship to Kantar Media
- Name of the person(s) to whom the report relates
- Date of the incident
- Place/location of the incident
- Specific details about your concern
- Any other witnesses involved
- Whether you have reported the concern to anyone else, including who
- Why you consider this is a reportable concern
- Your thoughts on the particular conduct issue
- The desired outcome you are seeking as result of making the report
- Any other relevant matters
Individuals making a report do not need proof of their suspicions in order to raise a concern. They must, however, have reasonable grounds to believe, given the circumstances and the information available to them at the time of reporting, that the matters they are reporting are true.
Personal data will be collected, processed and used only for handling the reported concern. Details of how your personal data is handled are set out in the RTS Privacy Notice.
Do I have to give my name?
You can make a report anonymously and we make every effort to investigate anonymous reports as far as possible.
For anonymous reports made outside SpeakUp, we can only rely on the information initially disclosed. A lack of sufficient information in the initial report may mean we are not able to investigate properly to adequately address the concern and improve our working practices and culture. For anonymous reports made via SpeakUp, we can raise comments, follow up and provide updates via SpeakUp which you should check weekly. This makes safe dialogue in an anonymous way possible.
Where appropriate, and subject to local law restrictions, we encourage reporters to provide their contact details. This is so the investigator can liaise with you to get relevant information to conduct a purposeful and meaningful investigation, recommend appropriate remedial action and let you know the outcome, if appropriate. Every concern raised, whether via SpeakUp or otherwise, will be treated confidentially, and will be promptly and thoroughly reviewed and, where appropriate, investigated.
I raised a concern, now what?
If you submit a concern, you will receive an acknowledgement of receipt within five working days. Your report will be evaluated and the appropriate course of action will be determined. Sometimes you will be asked follow-up questions. So far as possible, you will receive feedback within a reasonable timeframe and no later than three months after the acknowledgement of receipt of the report. Feedback may include:
- Whether an investigation will take place and if not, why not
- Whether it is appropriate in the circumstances for the matter to be dealt with under a policy in-market that aims to resolve complaints and disputes the individual reports
- An indication as to any other proposed way forward
- An estimate as to how long an investigation might take
- The result of any investigation i.e. whether the report was substantiated, not substantiated, incomplete or deemed frivolous
- Any recommended remedial action or follow up action to be taken
- If you choose to remain anonymous, we may provide details of a local contact that you can speak to should you wish to provide more information
Please note that we may not be able to give you details of the outcome of the investigation for reasons of confidentiality, privacy and the legal rights of the involved parties.
Please also note that not all issues raised will automatically lead to a formal investigation. Sometimes following another course of action is better for all parties involved (e.g. mediation). Furthermore, sometimes there is insufficient information for an adequate investigation to take place and there is no possibility of obtaining further information.
Confidentiality and protection for individuals raising a report
We are committed to ensuring that employees feel able to raise concerns openly under Right to Speak, without fear of reprisal, retaliation or victimisation and with the support of Kantar Media.
All investigations will be carried out confidentially to the fullest extent possible and with the appropriate level of sensitivity. Only a limited number of individuals will be aware of and/or involved in the investigation, unless Kantar Media is otherwise required or compelled by law to disclose information. Those knowing the identity of the individual raising the report will therefore be kept to a minimum.
Kantar Media does not tolerate any form of retaliation or victimisation in relation to a report being raised or involvement in a Right to Speak investigation. This is not only reprehensible and contrary to our culture, but it could give rise to legal action being taken against Kantar Media.
Retaliation includes not only actions taken by Kantar Media or any of our colleagues, but also actions taken by our clients or the recipients of our services and anyone working for them.
Examples of retaliatory action for making a report which will not be tolerated by Kantar Media include:
- Dismissal, suspension or any other disciplinary sanction such as a warning
- Demotion or withholding of a promotion
- Transfer of duties, change of location of place of work, reduction in wages, change in working hours
- Withholding of training
- A negative performance assessment or employment reference;
- Bullying or harassment
- Discrimination
- Failure to convert a temporary employment contract into a permanent one where the worker had legitimate expectations that he or she would be offered permanent employmentFailure to renew, or early termination of, a temporary employment contract
- Reputational damage
- Blacklisting on the basis of a sector or industry-wide informal or formal agreement, which may entail that the person will not, in the future, find employment in the sector or industry
- Early termination or cancellation of a contract for goods or services
- Cancellation of a license or permit
- Psychiatric or medical referrals.
Please note that this is not an exhaustive list.
Any retaliatory action will be taken extremely seriously and may result in a separate investigation and appropriate disciplinary sanctions against the perpetrator being taken. This is whether or not the initial report is found to be true.
If you believe that you have suffered or are the subject of retaliatory action please inform the investigator immediately or raise a report via this RTS process. This will then be discussed with the Kantar Media Legal Team.
Contact details and useful links
Raise your concern online here – https://kantarmedia.speakup.report/en-GB/raiseyourconcern/home
You can leave a report via phone. Please refer to this list for the correct telephone number for your country –
Please quote our organisation code when raising a concern via phone – 127070
Alternatively you can scan this QR code and raise your concern on your device –
