S172 (1) Compliance Statement

S172 (1) Compliance Statement – Duty to promote success of the company


All Response Media (ARM) is a member of the Vivendi group and 57% owned by Havas S.A. The company is bound by and applies Vivendi policies. Vivendi is an integrated content, media and communications group.

More details of Vivendi’s Corporate Social Responsibility ethos, policies, activities and results may be found at www.vivendi.com/en/social-responsibility/.

Anti-corruption Code

At Vivendi, all employees are required to comply with the laws and regulations in the countries in which they operate. The Group’s commitment in this regard is reflected in the implementation of a Compliance Program that covers personal data protection and anti-corruption measures, as well as obligations for monitoring the Group’s business activities.

An Anti-corruption policy has been drawn up to prevent and identify any potential risks situation. These rules apply to all Vivendi employees and all Group business partners (suppliers, subcontractors, intermediaries, etc.).

Vivendi Anti-corruption Code may be found at www.vivendi.com/wp-content/uploads/2018/10/Code-anticorruption-SIGNATURE-VA-021018.pdf.

Vigilance Program

Vivendi has implemented a Compliance Program which sets out general ethics rules which are applicable to each and every group employee.

These guidelines cover the rights of employees, the quality of information and its protection, the prevention of conflicts of interest, commercial ethics and the respect of competition rules, the use of group property and resources, financial ethics and respect for the environment. The objective of the Compliance Program is to make employees aware of their professional responsibilities, to provide them with a reference tool that helps them determine appropriate conduct.

More details may be found at www.vivendi.com/en/social-responsibility/specific-issues/ethics-and-business-practices/.


All Response Media

All Response Media is a leading performance media agency, building businesses and brands by giving clients an Unfair Competitive Advantage.

Corporate Social Responsibility and Code of Ethics

All Response Media’s Corporate Social Responsibility policy is coordinated at group level. More details may be found at www.havasgroup.com/csr/. In addition, Havas’ 2019 CSR Report may be found at www.havasgroup.com/havas-content/uploads/2020/04/havasgroup-csr-report-2019.pdf.

Ethics is the foundation of this Corporate Social Responsibility approach and the basis on which the group conducts its business. Havas Code of Ethics is aligned with expectations on the part of its stakeholders. Havas Code of Ethics is detailed at www.havasgroup.com/havas-content/uploads/2020/01/havas_codeofethics_2017.pdf.

Havas signed the Global Compact back in 2003 and continues to assert its commitment to the 10 main principles defined by the United Nations with regard to human rights, labour law, the environment and the fight against corruption.

All Response Media in conjunction with Havas has made corporate social responsibility an integral part of everything it does. Havas encourages its agencies to harness the power of creative ideas to bring about positive change and minimize any negative impact on society.

The Group has established six commitments to progress which guide all aspects of the business regardless of the nature of the work.

Havas is committed to:

  • promoting a harmonious and healthy working environment that supports collaborators’ growth and development;
  • reinforcing socially responsible procurement policies in our supply chain;
  • promoting transparency and ethics in our business;
  • taking the lead in the creation and diffusion of responsible communications throughout our agencies and in collaborations with clients and partners;
  • reducing the environmental footprint of our operations; and
  • maintaining our commitment to collaborative efforts in reducing climate change.

The directors of the company have taken all necessary steps to ensure that the company has implemented and complied with all Havas and Vivendi group policies and procedures.

Furthermore, the board constantly assesses the implications of decisions made, in terms of both the potential long-term consequences for the company, together with the impact on our stakeholders, including shareholders, employees, clients, suppliers and customers, the wider community and the environment.



The board communicates directly with Havas regarding the strategy and performance of the company through a number of different channels:

  • Regular and timely management accounts
  • Detailed and accurate financial budgets and forecasts;
  • Collaboration as part of the Vivendi cash management policy; and
  • Consultation and approval of any significant investment and acquisition decisions.


Employee engagement

The ARM board understands that All Response Media’s employees are our prized asset and should be supported and developed accordingly.

We give early ownership and responsibility to our employees to help service our clients, innovate and increase the efficiency of their customer acquisition. ARM works with its staff to learn not just about the planning and buying of media, but also our clients’ real business issues and strategies to improve outcomes – a real long-term personal development advantage. Our business is based on teamwork across all our offices.

In 2019, we embarked on an advanced Learning and Development plan, conducted across all our offices using both senior ARM managers as well as a significant amount of external accredited training events – all logged with the IPA’s CPD Training Programme.

This focused on a variety of management and Personal training topics:

  • Resilience, Time and Stress Management
  • Interviews and appraisals
  • Negotiation
  • Presentation
  • GDPR Training
  • Digital Performance
  • IPA Certificates
  • An internal mentoring program

This Training programme is being continued and expanded in 2020, with an increased focus on personal development, mental health and staff wellbeing.

We also introduced the Peakon engagement survey in June 2019 for a more bespoke and detailed staff engagement programme. We had an 85% participation rate from employees and our engagement score was 6.6; we are aiming for 7+ in 2020, so it is a good starting point. Moving into November we saw an improved participation rate of 90% and whilst we maintained our overall engagement score of 6.6, the more personal areas such as Work-Life Balance scores rose.


Health and Wellbeing

Our business also recognises the crucial importance of promoting positive health and wellbeing. It was this in mind that we widened the Training Programme to include stress management modules to the whole company, and as mentioned above, are expanding the training to include additional mental health modules. This will be for both for the whole company to identify signs and methods to avoid and resolve stress situations, but also for the Senior Management to build on solutions and identification to help the staff further.

We have also introduced several outside training sessions covering Meditation, Chair & Spinal Advice and greater usage of our staff benefits system, Perkbox.

Peakon feedback actions have been taken on board and include, but not limited to:

  • Charity Days that are not part of individual holiday entitlement;
  • Creation of more breakout areas in the office; and
  • Additional agency funded team events to build morale and teamwork.

Covid-19 has had a profound impact on all of our employees, who have been working from home since mid-March while our offices were closed due to the lockdown restrictions. The ARM board is continuing to look at our employees’ wellbeing and safety in these difficult times and are extremely proud of all of them for their teamwork, work ethic and resilience that they have shown while working from home.


Equality, Diversity and Inclusion

We strongly believe that racial discrimination should not be tolerated both in the workplace or outside of it. We believe that everyone has an equal opportunity to succeed at ARM. This starts with a fair and open workplace environment, offers unbiased staff hiring, and allows merit-driven personal development opportunities to all.

To ensure this is not only preached but actioned, we will be increasing our resources and attention to this area; encouraging wider listening, education and discussion to hopefully result in the right personal and company action.

We aren’t pretending that there isn’t more work to do, that we have all the answers or believe that things will change overnight. However, we do have the power and determination to use our collective strength to uphold important ethics such as equality, diversity and inclusion.

In 2019, we expanded our diversity training, mentoring, a feedback forum within the company, then moving into 2020 we are formalising a group that cuts across all levels of seniority that regularly meet to discuss not just Equality, Diversity & Inclusion @ ARM, but also explore other relevant initiatives to help build on our achievements so far: external speakers, wider recruitment via involvement with local colleges etc.


The community

We recognise that we have a responsibility to enact positive social change and can be both a mirror and an engine in society.

Some of our achievements to date within our community:

  • Supporting the homeless with our client, Centerpoint. An ARM team joined our client for a ‘Sleep Out’, sleeping outside for one night to raise money and awareness for the homeless. In total we raised over £3,000;
  • Every Christmas, having dropped our internal Secret Santa, we now have a GOSH Secret Santa. This involves staff individually buying presents for the children spending Christmas in Great Ormond Street Hospital;
  • Supporting and donating to the many charity events that our staff choose to get involved with from marathons to challenges to cycle rides;

In 2020 we have also started creating an ‘Outreach’ programme taking what we do to local colleges to highlight that it is an industry that they can be involved with and ARM is a leading company to grow at.


The environment

Since moving into our new offices in 2017 we have continued to progress our focus on recycling and furthering our green policies to make our business as environmentally friendly as possible.

Some examples of achievements we have achieved to date:

  • Recycling bins throughout the offices;
  • Promoting the use of saving paper, cutting printting down to a minimum;
  • Recycling printer cartridges, computers, batteries to name a few;
  • Motion sensor lighting;
  • Encouraging our employees to use to our Cycle to Work scheme; and
  • Encouraging our employees to use public transport wherever possible to attend clients and other external meetings.


Suppliers, customers and clients

The ARM board recognises that as a business we need to ensure that we are conducting our business in an ethical and transparent manner across all areas of the business, these include:

  • Anti-Slavery policy – Our policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help;
  • Recruitment policy – We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will;
  • Whistleblowing policy – We operate a whistleblowing policy so that all employees are encouraged to raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals. Details of the whistleblowing policy are included in our Employee Handbook; and
  • Supplier terms and conditions. We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work closely with our suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. Serious violations of the organisation’s supplier code of conduct will lead to the termination of our business relationship.

Risk assessment
On an on-going basis we conduct risk assessments to understand the risk in relation to slavery and human trafficking and believe there are no areas of concern. Given the nature of the services provided by us, we consider that we are at low risk of exposure to modern slavery and human trafficking.

Measuring effectiveness
We believe that by having received no reports from employees, law enforcement agencies or the public to indicate that modern slavery practices have been identified. We are taking every measure necessary to ensure its effectiveness within the business and our supply chain.

We have introduced within our HR induction for all new starters, including our Employee Handbook, how to identify the signs of modern slavery, how to assess the risk and the necessary steps to take if they suspect that it is taking place within our supply chain. This Handbook is distributed to all employees.

All Response Media Limited
Sutton Yard
65 Goswell Road

Email: info@allresponsemedia.com

2021 © All Response Media