Our client work

Marketing campaigns have the ability to influence views and
behaviour and can help to bring about positive change on social
and environmental issues. However, we must make sure we use
this influence appropriately, meeting high ethical standards in our
work and respecting human rights.

Fast read

Our Goal

We aim to help our clients engage more citizens and consumers on sustainability issues, while minimising ethical risks to WPP and our clients. We focus on:

  • Sustainability in marketing
  • Ethical standards
  • Human rights
  • Public policy and lobbying
  • Privacy and data security

Business value

Sustainability-related marketing services give us access to new business commissions and are a growing source of revenue for WPP.

Leading privacy practices enable us to access more business and reduce financial, legal and reputational risks to the business. Maintaining high ethical standards and protecting human rights safeguards our reputation and that of our clients.

Sustainability impact

Our sustainability expertise helps clients engage consumers on sustainability and increase the market for more sustainable business models, products and services.

Challenges and dilemmas

We work in 112 countries worldwide and must implement consistent standards even where local cultural practices or regulation differs, this includes when acquiring new businesses.

We rely on our people and leaders to make the right judgement in relation to ethical issues in client work and such issues are not always easy to identify or resolve.

Implementing leading privacy practices is challenging as technology and regulation in this area are both evolving rapidly.

Management approach

Our Code of Conduct, Human Rights Policy Statement and Sustainability Policy help our people in dealing with a wide range of ethical, social and environmental subjects. Employees are trained on these policies through our online ethics training. Detailed policies in relation to issues such as marketing standards are set at the local level. All companies must comply with WPP data and security policies, and WPP’s Data Code of Conduct. Our IT security (ITS) audit team monitors compliance.

Our deputy general counsel, litigation and compliance, oversees our approach to ethics and compliance, and provides support and guidance to our companies. She reports to our Group chief counsel and director of internal audit.

External frameworks

GRI indicators in this section: G4-15, G4-16, G4-34(M), G4-56(M), G4-HR2, G4-HR6, G4-HR9, G4-SO3, G4-SO4, G4-SO6, G4-PR7, G4-PR8

Global Compact Principles: 1, 2, 3, 4, 5, 6, 9, 10


Progress on our KPIs in 2015 Performance in 2015
£1.29 billion revenue from clients who engaged with WPP on sustainability Declined
200,000 employees completed WPP ethics training and anti-bribery and corruption training Stayed the same
Over 20,000 employees completed our SAFER DATA training new


Stayed the same   Stayed the same

Declined   Declined 

new   New KPI 

Sustainability in marketing

Our companies are working with clients on a growing number of briefs with a sustainability component. Our teams provide insight into new trends and opportunities such as the circular and sharing economies, and help companies integrate sustainability and purpose into their brands and communicate their commitment to consumers and stakeholders. Our sustainability in marketing work includes:

  • Research and insight: Providing insight into future trends, changing consumer attitudes to social and environmental issues and testing the impact of sustainability strategy and communications approaches.
  • Branding and strategy: Integrating social and environmental values into brand and business strategy.
  • Consumer communications: Helping clients communicate credibly with consumers and citizens on sustainability and generate sales of sustainable products.
  • Employee communications: Engaging internal audiences on social and environmental issues.
  • Stakeholder communications: Our public relations and public affairs companies help clients to communicate with regulators, the media, NGOs and the public on sustainability issues.

Many of our companies have established specialist sustainability offerings and social marketing units. These include: J. Walter Thompson Ethos, Ogilvy Social Change, OgilvyEarth, P&G’s S-Team, Young & Rubicam Group companies’ INSPIRE collaboration, Hill+Knowlton Strategies’ CR + Sustainability Communications, Kinetic Future and TNS Political and Social.

WPP the parent company supports our agencies to develop and share expertise in this area, including organizing events, publishing background briefings on our Group intranet and our Sustainability Navigator, a directory of sustainability expertise within WPP that enables collaboration across our companies.

Picture of George S. Rogers

George S. Rogers
Chief Client Team officer, WPP


The value of sustainability to business

“Brands who intend to be around for a long time need to think long term about their role in society and their purpose as a business.

Business with a purpose beyond just making profit can command greater customer and employee loyalty and ultimately be far more resilient. Resilience has a huge value in these days when the conversations about a brand can change in the push of an emoticon. 

Businesses that see their customers as more than just numbers create products and services that address customers’ real and changing needs and make a difference in people’s everyday lives. 

By integrating sustainability into their business they can prepare successfully for resource scarcity and climate change, rethinking business models and supply chains to be fit for the future. They can benefit from new markets for more sustainable products and services in areas like smart technology, alternative energy and the sharing economy. They will be the ones to benefit from a more circular economy in which continual reuse and recycling will provide access to new and more resilient streams of resources. 

This is a huge opportunity and, at WPP, our companies provide the insights, advice and communications services our clients need to make this transition successfully.”

Social marketing

Social marketing campaigns can raise public awareness and help bring about positive behaviour change in areas such health, safety and the environment. We work with many clients, including campaign groups and governments, on social marketing campaigns and have several companies with specialist units.

WPP companies work for the public sector in more than 60 countries. We have established a global Government & Public Sector Practice to drive excellence in our public sector communications, develop research insights and help governments better understand and engage citizens. See www.wpp.com/govtpractice. We also partner with leading schools of public policy to train future government leaders to use communication to drive long-term behaviour change. This includes teaching a compulsory module on Communications for Public Policy on the Masters of Public Policy (MPP) Program at the Blavatnik School of Government, University of Oxford. We also partner with the Lee Kuan Yew School of Public Policy in Singapore to provide an executive education program on Communications for Public Policy Delivery.

Recent client work

Cause-related marketing

Marketing campaigns have the ability to influence views and
behaviour and can help to bring about positive change on social
and environmental issues. However, we must make sure we use
this influence appropriately, meeting high ethical standards in our
work and respecting human rights.

Our thinking

WPP companies invest in thought leadership on sustainability, exploring how the power of marketing can be used to advance progress on social and environmental issues. New thinking and insights developed within our agencies can help clients achieve commercial goals, create brands with purpose and contribute to positive social change.

For example, new research, led by Rachel Pashley of J. Walter Thompson, explores the role of gender in marketing, with revealing new insights on the powerful impact of visible female role models. It makes a compelling case for more gender-balanced marketing, both as a means for brands to reach out more effectively to female consumers and as opportunity to advance women’s empowerment and economic development.

Marketing is often seen as being in conflict with achieving more environmentally-sustainable patterns of consumption. However, as Rory Sutherland, executive creative director at OgilvyOne explains in Marketing and sustainable consumption, marketing can actually play a positive role in moving society towards sustainable consumption, helping to make green and ethical choices normal and desirable.


The female delusion and Female Capital

Rachel Pashley
Group planning head
J. Walter Thompson, London

There’s never been a better time to be a woman, or so say 76% of women in our proprietary Women’s Index1. We’re all familiar with the idea of women as consumers, with current estimates suggesting that women control up to two-thirds of the global consumer spend – but what we’re perhaps less familiar with is the idea of women as wealth creators in their own right: the fact that China is home to two-thirds of self-made female billionaires, or that women run eight out of the 10 leading banks in India – effectively placing the control of 40% of India’s assets in the hands of women.

All too often discussions about the struggle for gender parity tend to paint women as passive victims of discrimination, and whilst this is undoubtedly a cultural truth, focusing solely on this narrative can disempower women: and it’s deluded as to the power and influence women already wield in the world. We at J. Walter Thompson Company believe in a second truth: the idea of Female Capital, the value that women deliver to the world – as women. We believe that Female Capital will be transformational not just for brands and business but for the world at large. Let me explain.

The ‘Dow Jane Effect’ and the female economy

Evidence of the ignorance of Female Capital exists all around us. Research from Vanderbilt University2 examined attitudes to women as leaders, and concluded that women were perceived as assistants and support staff, but poor leadership material. In fact, the opposite is true. Women are the more efficient leaders – with efficiency peaking as they get older3 , perhaps explaining why a 2016 global study by the Peterson Institute concluded that companies with more women in leadership positions are more profitable4.

So entrenched beliefs not only deny women a seat in the boardroom but can actually weaken the bottom line on the balance sheet. If you needed any more persuasion, consider that, on average, female-led hedge funds consistently out-perform those managed by their male peers 5. In 2009, in recognition of this ‘Dow Jane Effect’, Naissance Capital, a global investment company, introduced gender diversity screening for investment funds to prioritise those with women on the boards. Retailer Walmart, has started to actively promote female-owned businesses via a labelling system, recognising through their own studies that women are significantly more likely to purchase products made by women, citing quality as a key motivation. Women recognise and support the idea of Female Capital even if the corporate world has yet to catch on.

However, a quiet revolution is happening: a 2013 study published by Amex, revealed that in the US not only are women starting their own businesses at twice the rate of men, they are also growing big businesses. Women-owned businesses in the $10m+ category have growth rates outstripping their peers and display the fastest growth rates – well above average6, perhaps contributing to the fact that 60% of all personal wealth in the US is held by women. Let me repeat... that’s 60%.

Female Capital in action: Bepanthen 10th Month

Recognising that new mums often feel invisible, J. Walter Thompson created ‘10th Month’, an initiative with Bayer’s Bepanthen nappy care ointment brand. This aimed to support the woman ‘behind’ the mother, at one of the most vulnerable times of her life: the post-partum period. For a babycare brand to talk not to the mum, but to the woman, is ground-breaking. Within 24 hours of launch our 10th Month film had achieved over 130,000 views.

The value of cultural capital

Let’s consider another example, and look to Hollywood. Until recently, the prevailing wisdom was that ‘male’ action movies were a safe source of box office revenue – the assumption being that cinema audiences were primarily male and teenage. In fact 52% of the cinema audience in the US are female7, and the earnings potential of male-centric movies has stalled (Ted 2, Hercules). A decade-long analysis of box office earnings concluded that female-led films consistently out-performed their male equivalent 8 , by a considerable margin. Yet, on average, only 30% of women’s film roles were speaking parts: apparently silent movies are alive and well, for women. To state the obvious, this is a disservice to women culturally, but it is also a huge untapped source of sustainable revenue because women want to see films with strong female role models: they want to be visible.

From our own research, 80% of women globally said they wanted women to have a louder voice in culture. By serving societal need, Hollywood gets to build a sustainable future, with the screenwriters guilds predicting that the ‘Female Myth’ archetype is set to be the dominant narrative for the next 20 years9, Hunger Games and Inside Out being stellar examples. That’s great news for the studio bosses, but what about the rest of us?

The legacy of female role models

Well this is where things get interesting. Female Capital doesn’t just benefit the corporate world. The impact of on screen female role models can shape not just women’s career choices but their life choices: and it’s nothing short of game changing. Our research discovered that 58% of women globally said that seeing strong female role models on screen (film and TV) made them more ambitious or assertive and 60% claimed that role models had influenced their career choices from taking a leadership position through to fields of study. But then we made a discovery so profound it took our breath away: role models were impacting life choices. Our research revealed that one in four women in Brazil said they were inspired to leave an abusive relationship: just through the influence of a female onscreen role model. Now, anyone in the business of advertising will understand the persuasive power of the moving image, but this was startling, especially when you consider that one in three women in Brazil experience domestic violence10. Let’s consider what that could mean for the world.

How to solve extreme poverty... through advertising?

It’s estimated that domestic violence costs the global economy $8 trillion every year11, and what could $8 trillion do? Well, Goldman Sachs estimated that to end worldwide extreme poverty would take 20 years, at a total cost per year of $175 billion, so roughly (and OK we’d need to adjust the costs for inflation but all things being equal), solving extreme poverty would cost $3.5 trillion. But remember, if we solved domestic violence we just saved $8 trillion, or even halved the incidence – that’s $4 trillion. So we could conceivably solve extreme poverty: through onscreen female role models. By onscreen role models we mean film or TV series, but also advertising or brand content. Consider the possibilities.

This is why at J. Walter Thompson, we believe in recognising women, not in terms of their (parental) responsibilities: i.e. ‘The Busy Working Mum’, but celebrating their achievements and aspirations. We are exploring the possibilities as part of our Female Tribes initiative, using the results of a three-year global study. We believe that changing the cultural conversation will be game changing.

Complacency is not an option

Advertising is part of culture, and beamed into virtually every home around the world. This gives us an opportunity and a responsibility to positively influence culture. To paraphrase the UN: an empowered women is the most potent force for change, and I would offer that by harnessing Female Capital in its broadest sense, we can build a sustainable future.

Female Capital in action: Her Story

As part of our intent to change the cultural conversation, J. Walter Thompson Entertainment partnered with BBC World News and Films of Record to produce a four-part TV series. Her Story: The Female Revolution tells the global story of female progress, a retelling of contemporary history through a female lens, based on the insight that women’s achievement is frequently airbrushed from history. Her Story features some of the most powerful and influential women of our time – the new female role models.

  1. JWT Women’s Index 2015
  2. http://link.springer.com/article/10.1007%2Fs11109-014-9274-4
  3. Zenger Folkman Leadership Effectiveness Study 2012
  4. http://www.piie.com/publications/wp/wp16-3.pdf
  5. 2013 Rothstein Kass
  6. Growing Under the Radar: An Exploration of the Achievements of Million-Dollar Women-Owned Firms, American Express OPEN January 2013
  7. Motion Picture Association of America
  8. http://mic.com/articles/127095/here-s-exactly-how-much-movies-about-women-make-at-the-box-office-versus-movies-about-men#.GxETarKMf
  9. John Truby, Page Screen Writing Awards
  10. http://www.aljazeera.com/programmes/women-make-change/2015/09/150921120805489.html
  11. http://www.reuters.com/article/us-abuse-costs-idUSKBN0H41AL20140909


Marketing and sustainable consumption

Rory Sutherland
Executive creative director, OgilvyOne
and vice chairman, Ogilvy Group, UK

The sum of the world’s wealth is not really expressible as a numerical figure and is imperfectly related to monetary wealth. It is really the sum of the rewarding choices which people can easily and confidently make.

It is fairly easy to prove this through a simple thought experiment – you simply imagine a wealthy man living in a small village on an isolated island. It is easy to see he may be significantly worse off than someone living near a large interesting town with only half the money.

Most economic discussion revolves around how to generate more money, with almost no thought given to how people might make better choices with the money they already have. Yet, rather than growing economic wealth, helping people make more varied and better choices with the wealth they have might be a relatively easy alternative approach to improving human well-being without increasing consumption.

In the last 20 years or so, we have begun to understand better than before the way people choose, and the psychological mechanisms at work in human decision-making. This should give marketing a new lease of life. Wherever there exists a valuable possibility which people never adopt or even consider because of some psychological hurdle, there is a chance for marketing to create wealth from pre-existing resources simply by removing that barrier. The good news is that the world is full of such examples.

The opt-out pension is a good example of creating a palatable choice where none existed before. For simple psychological reasons (we are a social species) we find it much less nerve-wracking to do things if other people are already doing them. Buying an individual pension for yourself is terrifying. Joining a scheme together with all your mates at work is relatively reassuring. Even if the two pensions are indistinguishable in financial terms, the individual one is far less appealing than the collective one.

Or take the London Overground. Here was a railway line which had existed for years under the name Silverlink Metro. Nobody used it. Renamed the Overground and added to the Tube Map, it suddenly became a salient option. Within a month of this change, usage increased fourfold.

Marketing has a wonderful alchemical power to create options and possibilities as if out of thin air. Brands have the spectacular power of making brave choices seem safe. “Would you like this electric car?” “No.” “What if it’s from Ford?” “I’ll take a look.” “Solar panels?” “No.” “They’re from John Lewis.” “Oh...”

If we want people to change their behaviour, and to adopt more pro-social behaviours, making those new choices salient, appealing and non-weird is not an add-on, where marketing is retro-fitted as the last little bit of magic dust. It’s the first place we should look.

A version of this perspective first appeared in The Drum, www.thedrum.com

Investing in creativity

Our companies create opportunities for employees to be inspired by new ideas, and learn from experts and innovators in a range of fields. This supports their development and helps our teams produce leading work for clients. Examples include Ogilvy Group UK’s Ogilvy Labs, a research and development facility that exposes employees and clients to inspiring new ideas, seeks out new partners and nurtures new business ventures. It runs regular events such as Lab Days and Lab Lunches for employees and partners. At Hill+Knowlton Strategies London, the Collider Program helps put change, innovation and creativity at the heart of the agency and its client work, encouraging participants to become intrapreneurs and help define the future direction of the agency.

The Store is the WPP global retail practice and it helps WPP companies innovate and challenge the conventional in the retail arena. The Store holds seminars, hands-on innovation technology sessions, thought leadership programs, develops partnerships and helps nurture innovative technology start-ups in the retail space. Its newest innovation, the ‘Internet of Things Innovation Kit’, empowers the creative community across the WPP Group to understand how the internet of things is set to change retail. Teams can use the kit to rapidly prototype new ideas that solve client problems, without having to know anything about computer code.

We also recognise and reward our employees for their creativity. For example, the WPP WPPED Cream Awards recognise the very best creative work produced by WPP companies in all disciplines across nine categories. See www.wpp.com/wppedcream. Our Atticus Awards honour original thinking in communications from Group professionals. Category winners receive a cash prize and extracts from the winning and other outstanding entries are published in the Atticus Journal, now in its 22nd year.

The creativity and effectiveness of our work for clients has been recognised in a number of major awards including winning: the Effie Most Effective Holding Company award for four consecutive years in 2015; the top holding company in Warc’s 100 annual ranking of the world’s best campaigns and companies for the second consecutive year; and Holding Company of the Year at the 2015 Cannes Lions International Festival of Creativity for the fifth year running.

Our ethical standards

The WPP Code of Business Conduct provides the framework for how we operate. It establishes the values and ethical standards that all our companies must implement, including zero tolerance for bribery or corruption.

It is supported by our Group Sustainability Policy, Human Rights Policy Statement and detailed policies on topics such as anti-bribery and corruption, gifts and entertainment and the appointment of third-party advisors. You can read our Code of Business Conduct.

Senior managers in all our companies and our business partners and major suppliers are asked to sign a copy of the WPP Code of Business Conduct each year to confirm they will comply with its principles. Breaches or alleged breaches of the Code are investigated by the director of internal audit, head of compliance, the Group chief counsel and external advisers where appropriate.

Employees can report concerns or suspected cases of misconduct in confidence through our third party-managed Right to Speak facility, overseen by our legal and internal audit departments. This is publicised through induction packs, the Group intranet, the WPP Policy Book and our ethics training. There were 60 calls made via Right to Speak during 2015, all of which were followed up, investigated where appropriate and reported to the Audit Committee.

We have a Group-level committee that meets regularly to discuss ethical and compliance issues and new risk areas. Committee members include the Group chief counsel, deputy general counsel, litigation and compliance, Group finance director, the head of talent and the head of sustainability. The committee also reviews potential client-related risks such as bribery and corruption, data privacy and competition rules. The committee met on three occasions in 2015.

Ethics training

Our ethics training, ‘How we behave’, is compulsory for all employees. It covers topics such as diversity, privacy, human rights and avoiding misleading work. Our online training on anti-bribery and corruption covers the Foreign Corrupt Practices Act and UK Bribery Act on issues such as hospitality and gifts, facilitation payments and the use of third-party advisors. Training is updated every 2-3 years and employees are required to repeat the training following each update.

Over 200,000 employees have completed our anti-bribery and corruption training and almost 200,000 have completed our ethics training since the last update in 2013. These figures are higher than our current number of employees as they include some employees who have since left the business. The training will be updated again in 2016. Acquired businesses enter into contractual commitments to comply with WPP policies and to undertake the Group training programs within a short time-frame of joining the Group.

Associates and partners

We expect associate companies (those in which we hold a minority stake) and affiliate companies (preferred partners to whom we may refer business) to adopt ethical standards that are consistent with our own.

We expect suppliers to meet high ethical standards and we require all major suppliers to sign our Code of Business Conduct – Supplier Version, which interprets our own Code for our supply chain.

Acquisitions and sensitive countries

Our due diligence process for acquisitions and expansion into new markets includes a review of ethical risks including those relating to bribery and corruption, human rights or ethical issues associated with client work. We take steps to ensure that acquired businesses embed our policies and undertake our ethics training. We enter into contractual commitments to comply with WPP policies and to undertake the Group training programs within a short time-frame of joining the Group.

We use a variety of sources to understand and manage any risks associated with different countries of operation, including the Transparency International Corruption Index, Human Rights Watch country reports and any relevant governmental guidance. We comply with all relevant sanctions regimes.

Compliance with marketing standards

We expect our companies to comply with all relevant legal requirements and codes of practice for marketing standards in the work they produce for clients. A very small number of the campaigns we produce give rise to complaints, some of which are upheld by marketing standards authorities. Our agencies monitor complaints and take action where needed to prevent a recurrence.

Attitudes to subjects such as taste and decency evolve, and new issues can arise as technology develops. Our companies participate in industry groups and help to develop and evolve codes of practice for the marketing industry.

Ethical decisions in our work

Our work for clients can raise ethical issues. This could include, for example, work for government clients in sensitive countries, or marketing for sensitive or controversial products. We expect all our people and companies to maintain high standards of integrity and honesty and to take particular care in areas such as marketing to children, or when producing work for products or sectors that are potentially sensitive.

We have a review and referral process to help our people consider the ethical impact of our work and to make decisions about new commissions that reflect our standards. This can include turning down work which presents an unacceptable ethical risk to WPP or our clients.

Before accepting a potentially sensitive commission, employees are required to elevate the decision to the most senior person in the relevant office and then to the most senior executive of the WPP company in the country concerned. They will decide if further referral to a WPP executive is required.

Companies also have copy-checking and clearance processes through which campaigns are reviewed by the legal team before publication. Requirements are particularly comprehensive in sectors such as pharmaceutical marketing that are highly regulated.

Client ethics is one of the topics covered in our ethics training which helps employees identify ethical risks associated with client work, and raises awareness about referral procedures. Depending on scope, internal audits may incorporate a review of the consideration given by management to possible impacts on the Group’s reputation prior to accepting new clients.

Human rights

Respect for human rights is a fundamental principle for WPP and we take steps to prevent, identify and address any negative human rights impacts associated with our business as well as looking for opportunities to positively promote and support human rights.

To confirm our commitment to human rights, during 2015 we published a human rights policy statement and joined the United Nations Global Compact. You can read our Global Compact Index, which shows how we re reflecting its 10 principles in our business.

Our human rights impacts and opportunities

Our main human rights impact is as a major employer in 112 countries and we aim to embed respect for human rights into our employment practices. This includes providing safe workplaces, selecting and promoting our people on the basis of their qualifications and merit and encouraging diversity. We recognise the rights of our employees to freedom of association and collective bargaining and will not tolerate discrimination, harassment or any form of forced, compulsory or child labour. More information is available in our Employment section.

We also have a number of indirect human rights impacts. We can positively influence human rights standards in our supply chain, particularly for on-site contractors, by working with our suppliers and setting clear expectations on human rights. Client marketing campaigns can have an impact on human rights and, where relevant, we work with our clients on these issues. This includes protecting children’s rights in relation to marketing. WPP companies will not undertake work designed to mislead on human rights issues.

Communications campaigns can be used to raise awareness of human rights issues and to encourage action to protect human rights. Our agencies provide creative services to organisations involved in protecting and promoting human rights, often on a pro bono basis. This is our main opportunity to positively promote human rights. Examples are included in our Pro bono book, wpp.com/probonoreport2015-16

Our direct and indirect human rights impacts on employees, on-site contractor, workers in our supply chain and Citizens and consumers impacted by our client campaigns and pro bono work for human rights organisations

Our policy and standards

Our Human Rights Policy Statement was published during 2015 and integrated into our Policy Book that all our companies must comply with. It reflects international standards and principles including the International Bill – Human Rights, the UN’s Guiding Principles on Business and Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and the Children’s Rights and Business Principles. The policy is available on our website, see www.wpp.com/wpp/sustainability/policies-and-resources/.

During 2016 we will review other relevant policies to confirm that they align with our position on human rights. We are adding a number of scenarios to our online ethics training that cover human rights-related issues including non-discrimination, marketing to children and human rights in the supply chain. This training is completed by all employees.

We expect suppliers to adopt similar human rights standards to our own and all major suppliers are asked to sign our Code of Business Conduct – Supplier Version, which includes human rights requirements. See Supply chain for more information.

Anti-trafficking and slavery

A growing number of client contracts now include clauses relating to anti-trafficking and modern slavery. The UK has introduced the Modern Slavery Act which will require all companies to explain their approach to preventing slavery in their operations and supply chain. Similar legislation exists in the US.

As a professional services firm the risk of trafficking or slavery in our workforce is very low. However, we issued guidance to our operating companies in early 2016 reiterating that we do not tolerate people trafficking or forced labour, and providing examples of risk areas. We updated our Code of Business Conduct to reflect this.

We will publish a statement in relation to the UK’s Modern Slavery Act explaining how we assess and manage risks relating to slavery in our operations and supply chain.

Living wage

We support the principle that full-time workers should be paid enough to provide a decent standard of living. This principle is known as the ‘living wage’. In the UK, the Living Wage Foundation, a not-for-profit organisation, has calculated a voluntary living wage rate, which exceeds the UK’s current statutory national minimum wage.

As a professional services firm, the vast majority of our employees already earn significantly above the living wage rate. However, wage rates in our supply chain may be lower. We clarified our position on this issue in the UK during 2015. It is now our policy in the UK for WPP, the parent company, to pay the living wage for all parent-company employees and all on-site contractors such as cleaning, security and catering staff. Our UK agencies are working towards paying the living wage for all employees and on-site contractors within three years and several already do so.

Public policy and lobbying

The business community can make an important contribution to the debate on regulation and government policy. However, to protect the public interest, it is important that business lobbying is conducted with honesty, integrity and transparency.

We have a number of public affairs businesses that carry out public policy work for clients, including direct lobbying of public officials and influencing public opinion. Our public affairs companies include: Burson-Marsteller, and its affiliates: Prime Policy Group, Direct Impact and Penn Schoen Berland; Finsbury; Glover Park Group; Hill+Knowlton Strategies, and its affiliates: Dewey Square Group and Wexler & Walker Public Policy Associates; OGR; QGA. The majority of their work takes place in the US and the EU, although many of our clients are multinational companies.

On occasion, we also engage in the public policy process on issues that affect WPP and our companies. This section explains our approach to political activities in both areas.

Our standards

We recognise the importance of transparency and high ethical standards in our public policy activity. We are governed by our Code of Business Conduct, which commits us to acting ethically in all aspects of our business and to maintaining the highest standards of honesty and integrity. In all instances, we respect national laws and any other laws with an international reach, such as the UK Bribery Act and the US Foreign Corrupt Practices Act, where relevant, and industry codes of conduct. We also have more detailed policies on issues such as hospitality and gifts, facilitation payments and the use of third-party advisors.

In addition, many of our companies are members of professional organisations and abide by their codes of conduct. Examples include the UK’s Association of Professional Political Consultants (APPC), the self-regulatory body for UK public affairs practitioners, and the European Public Affairs Consultancies’ Association (EPACA) the representative trade body for public affairs consultancies working with EU institutions.

In relation to our work for clients, WPP companies comply with all applicable laws and regulations governing the disclosure of public affairs activities. In the US, this includes the Lobby Disclosure Act and the Foreign Agent Registration Act, which are designed to achieve maximum transparency on client representation and require lobby firms to register the names of clients on whose behalf they contact legislators or executive branch personnel. A number of our agencies are listed on the voluntary EU Transparency Register of lobbying activities.

It is WPP’s practice that those of its US companies whose sole or primary business is lobbying have representatives of both major political parties among senior management.

We will not undertake work that is intended or designed to mislead. We do not knowingly represent ‘front groups’ (organisations which purport to be independent NGOs but are controlled by another organisation for the purpose of misleading) and seek to ensure we are aware of who the underlying client is before taking on work.

Mark Linaugh, chief talent officer, has overall responsibility for our public affairs practices and ultimate responsibility for our political activities rests with our Board. We have a Group-level committee that meets regularly to discuss ethical and compliance issues including in relation to political activities.

Any associates carrying out political activities on our behalf are expected to comply with our Code of Conduct and other relevant policies.

Political contributions

WPP the parent company does not make political contributions. WPP companies do not make political contributions from corporate resources with the occasional exception of very small, lawful contributions to local candidates or parties in the US or UK. No corporate contributions of any kind, including the provision of services or materials for less than market value, may be made to politicians, political parties or action committees, without the prior written approval of the WPP Board.

In countries where it is consistent with applicable law, individuals working at WPP make personal voluntary political contributions directly to candidates for office. Several of our businesses, including Burson-Marsteller, Glover Park Group, Hill+Knowlton Strategies, Prime Policy Group and Wexler & Walker, also maintain political action committees (PACs) which accept voluntary donations from employees to support political candidates. $169,332 was given through these PACs to federal candidates during 2015 and early 2016.

Lobbying and political advocacy

On occasion, WPP engages in the debate on public policy issues relevant to our business, sometimes operating through our public affairs companies. This can include issues specifically relevant to our sector as well as issues that can affect the general business environment. A recent example is the debate on the UK’s membership of the European Union, with WPP expressing support for the UK to remain within the EU. Our companies also contribute to public debate in areas where they have expertise and a special interest – our digital and research companies, for example, get involved on privacy and data protection issues.

We engaged with peer companies and governments in 2015 on a number of sustainability issues. For example, we participated in an initiative of the International Chamber of Commerce to support the United Nation’s Sustainable Development Goals and encourage political leaders to work with business to implement the goals. Sir Martin Sorrell, WPP’s CEO, also spoke publicly on a number of relevant topics including sharing a platform with Al Gore at the Cannes Festival to discuss the importance of climate change and with Lord Browne at an event to highlight the importance of LGBT inclusion for business.

We follow government rules in relation to ‘cooling-off’ periods for employees joining WPP from public office or the public sector.

Membership of trade associations and public policy groups

We are members of trade associations, industry groups and memberships organisations which undertake lobbying activity on behalf of their members. At a parent company level our memberships in the US include the American Benefits Council, British American Business Inc, British American Business Council, The Business Council, Business Roundtable, Centre for Talent Innovation, Council on Foreign Relations, Northeast Business Group on Health and the Wall Street Journal CEO Council. In the UK they include the All Party Parliamentary Corporate Responsibility Group, British American Business London Transatlantic Council, CBI, Chambre de Commerce Française de Grande Bretagne, China Britain Business Council, Institute of Business Ethics, Trilateral Commission and Women on Boards.

Privacy and data security

Consumer data is used extensively in developing, implementing and monitoring marketing campaigns and is particularly important to the services provided by our digital marketing and insight businesses. It enables our companies to create tailored marketing, improves consumer engagement and allows for more accurate measurement of the effectiveness of campaigns.

When collecting, using and storing consumer data, we need to implement rigorous data protection and security procedures to protect consumer privacy, comply with data protection laws and safeguard the reputation of our clients and of WPP. This topic is of increasing interest to clients, regulators and investors.

We also work with our peers, clients and industry bodies to improve privacy practices including the W3C Tracking Protection Working Group and the Interactive Advertising Bureau.

Our standards

All WPP companies must follow the WPP Data Code of Conduct as well as our global IT security, privacy and social media policies. Our Data Code of Conduct provides a clear framework for all our agencies to implement privacy best practice.

Our WPP Client Contract Toolkit helps WPP companies understand how privacy and data protection criteria should be integrated into client contracts.

Any supplier who collects, manages or stores consumer or client data on behalf of WPP companies and our clients must have the right data security and privacy standards in place. We are also identifying and managing data privacy and security risks in our supply chain, working with Sedex, (the sustainability supply chain platform), see Supply chain.

Changes in technology create new privacy risks and we keep our approach and the guidance we provide to our agencies under continual review.

Raising awareness

Safer Data screenshot

We launched SAFER DATA in 2015, a privacy and security awareness campaign and online platform with information and guidance for employees on the importance of privacy risk and data security. This covers topics such as phishing, safe file sharing, avoiding rogue wifi networks and setting strong passwords and uses a humorous short video to engage employee attention. Launched by WPP’s CEO, it is intended that SAFER DATA become the platform for know-how on privacy risk and data security at WPP. It includes a ‘SAVEMYDATA’ reporting tool, to allow our people to raise concerns and questions they have about data issues direct with our in-house legal teams.

We also launched mandatory global online Privacy and Data Security Awareness training. Over 20,000 employees completed the training in the first two months following launch.

Monitoring implementation

We have a central team of legal, audit and compliance professionals who support WPP companies on privacy. Our internal audit team reviews privacy risks and practices as part of its Group-wide audit program, focusing on different companies each year.

We used our Data Health Checker in 2015 for the third year running to review privacy risks and data security practices in our businesses. The results showed us that the majority of our companies have strong mitigation measures that match or exceed their level of privacy risk, with the average score being 3.9 out of 5, where 5 is the maximum score possible. Of those companies surveyed, 74% have a dedicated privacy lead and 51% have trained all of their people on data security and privacy in addition to Group training.


Our principles

WPP, its companies and its people are committed to responsible collection, management, use and protection of data.

WPP recognises its obligations to all its stakeholders including share owners, clients, its own people, suppliers and consumers.

WPP works with many categories of data and uses the term data in its broadest sense. We include within this definition client data, consumer data and all information and data related to the operation of our businesses.

Our practices

  • We will be transparent with consumers.
  • We will treat data in accordance with all applicable laws, regulations and treaties.
  • We will implement fair and reasonable data policies and procedures.
  • We will treat data as confidential.
  • We will understand not only what data we hold but also its relevance to stakeholders.
  • We will secure, collect, process, use and store data appropriately.
  • We will ensure that data is retained appropriately.
  • We will implement necessary and appropriate technical measures to secure data.
  • We will delete data when required to do so.
  • We will ensure our people understand their role in upholding these principles and practices.