Anti Slavery

Digital Cinema Media

Limited Anti-slavery and human trafficking statement

January 2023

The Modern Slavery Act 2015 (Act) requires any commercial organisation in any sector, which supplies goods or services, and carries on a business or part of a business in the United Kingdom, and is above a specified total turnover, to produce and publish an annual slavery and human trafficking statement.

This statement relates to the actions and activities of Digital Cinema Media Limited (Company) and all of its subsidiaries during the financial year 1 January 2022 to 31 December 2022 (DCM’s financial year ended on 22nd December 2022). Where the context so requires, references in this statement to the Company include references to the Company and all of its subsidiaries from time to time. The Company is committed to the prevention of the use of forced labour and has a zero-tolerance policy for human trafficking and slavery.

  1. Organisational structure
    Digital Cinema Media is the market leader in UK cinema advertising, providing over 3,500 screens at over 500 sites for advertisers. The Company sells 80.1% of the cinema advertising market through exhibitors including Cineworld, ODEON, Vue, Picturehouse Cinemas and many independent cinemas. The Company employs around 65 staff members who are all based in the UK. The vast majority of the Company’s exhibitors are well known UK brands.
  2. Our policies on slavery and human trafficking
    1. The Company will not use or allow the use of forced, compulsory labour, slavery, servitude or human trafficking in the course of its business.  This includes sexual exploitation, securing services by force, threats or deception and securing services from children and vulnerable persons.
    2. The Company operates the following policies which are relevant to the prevention of slavery and human trafficking in its operations:
      1. Anti-slavery and human trafficking policy – this policy sets out the steps that the Company has taken, and will take, to prevent human trafficking and slavery within its business and its supply chain.
      2. Employment Policy - Employment terms and conditions for the Company’s employees based at its UK offices are regulated by and are operated in compliance with all relevant prevailing legislation. Employment terms and conditions provided to staff are better than the national average. The Company is recognised by both The Sunday Times and Campaign Magazine as a Best Place to Work and for creating an environment where people love to come to work.
    3. In addition, internal policies are reviewed regularly to ensure continued compliance with the Modern Slavery Act 2015.
  3. Due diligence processes for slavery and human trafficking
    The Company believes that in order to prevent human trafficking and slavery within its business and its supply chain it is necessary to first understand the areas where the Company is most at risk. Due to the Company’s exclusively UK based operations and the fact that its suppliers are mostly large UK based cinema chains the Company believes that the risk of modern slavery occurring in its business or in its supply chain are very low. The Company is, however, committed to ensuring that that is, and remains, the case and has implemented systems to:
    1. continually seek to identify and assess potential risk areas in the Company’s business and supply chains; and
    2. protect whistleblowers.
  4. Supplier adherence to our values and ethics
    1. Efforts are made to confirm that the Company’s suppliers are as committed to the prevention of human trafficking and slavery as the Company, and each supplier’s conduct is carefully considered when awarding or renewing business.
  5. Performance indicators
    The Company will use the following key performance indicators to measure how effective it is in ensuring that slavery and human trafficking is not taking place in any part of its business or supply chain:
    1. completion of necessary training of the policy by all relevant staff;
    2. communication of the policy to suppliers; and
    3. the response time and remedial actions taken by the Company in respect of any reported case of modern slavery or human trafficking within its business or supply chain.
  6. Further steps
    This statement will be reviewed annually by Jemma White.

This statement is made pursuant to section 54(1) of the Act and constitutes the Company’s anti-slavery and human trafficking statement for the financial year ended 31 December 2018.

Jemma White
January 2023