Modern Slavery and Human Trafficking Statement 2024
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps we have taken to ensure that our business as well as our supply chains are free from slavery and human trafficking during the financial year ending 31st December 2023. This statement applies to Dailymotion SA including all its Dailymotion subsidiaries (together “Dailymotion”).
Dailymotion is committed to act ethically and with integrity and has made proper commitments in its Human Rights Policy on human rights matters including modern slavery for which Dailymotion takes a zero-tolerance approach.
We firmly believe in the inherent dignity and equal rights of all individuals as listed in the Universal Declaration of Human Rights and recognize the importance of meeting the expectations for businesses as set out in the United Nations Guiding Principles on Business and Human Rights (UNGPs).
The Vivendi Group, which Dailymotion is part of, has joined the United Nations Global Compact in order to support and apply throughout all its entities, the respect of the 10 Principles of the UN Global Compact. These fundamental principles are related to human rights, labor law, environmental law, and the fight against corruption.
In terms of labor law, Dailymotion is strongly committed against child labor and forced labor and is committed to respecting rules on working time, wages and benefits, freedom of expression, equal opportunities, etc.
Dailymotion is also committed to respect human rights as stipulated in the following international conventions such as:
Dailymotion is member, signatory and/or supporter of:
- The Tech Against Terrorism initiative
I – Organization structure and supply chains
Dailymotion was founded in 2005 : it’s a global video streaming service that connects over 350 million entertainment-seekers to their personal world of news and entertainment. Dailymotion is a video platform, an application, and also a player video technology. Dailymotion Advertising offers its own video advertising solutions that cover the entire marketing funnel.
With more than 390 employees, our platform is available worldwide with more than 400 million users each months for 3.8 billion monthly video views.
Dailymotion is owned by Vivendi and headquartered in Paris with offices in New York, Singapore, Sophia Antipolis and Montpellier.
Dailymotion is an innovative video streaming service that offers the best technology to its customers. We have various types of clients for our BtoB services from the big leading companies to little agencies around the world.
To achieve these goals and support our activities, we rely on various products and services including but not limited to :
- Cloud storage services
- Moderation Services
- IT infrastructure and network services and equipment
- Advertising services
- Human Resources, legal and financial services, etc.
II – Governance, Policies and Procedures
Vivendi and Dailymotion have deployed several policies and procedures, applicable to its own employees but also to our suppliers and users, related to human rights protection and notably aimed at tackling modern slavery.
1. Prohibited Content Policy
Our Prohibited Content Policy, which is an integral part of our Terms of Use, is covering a very broad range of issues, including but not limited to: protecting children’s rights; combatting harassment and hateful conduct; content glorifying, trivializing, or denying a crime; fighting false or misleading information; terrorist content and/or content which promotes violent extremist acts, groups or individuals; content that incites violence or dangerous activities; spam, scam, or fake engagement; copyright infringement.
More specifically, our Prohibited Content Policy forbids our Users to post any content contributing to the exploitation of people, such as content depicting forced labor, domestic servitude, human trafficking, including for sexual exploitation, slavery and/or pimping.
To enforce this Prohibited Content Policy, we have put in place a reporting mechanism open to everyone. All reports are reviewed by our moderation team, working 24/7, and composed of experienced professionals. In case of disagreement regarding a moderation action, all parties are entitled to file an appeal.
Dailymotion limits the access to its livestream feature to its premium partners only. This measure considerably reduces the risk associated to the diffusion and spreading of violent content on the Internet.
Dailymotion has a zero-tolerance policy for content involving children being physically abused or sexually exploited. As such, if an account is found to have shared such content, the content will be immediately removed and the account will be promptly terminated. Furthermore, if Dailymotion believes a child is in danger, we will report the content to law enforcement and assist with any investigations. You can learn more about Dailymotion’s Child Safety Policy here.
2. Vigilance Plan
In accordance with the law on the Duty of Care, the Vivendi Group has strengthened its measures to prevent risks and mitigate serious harm that could be caused by the Vivendi group’s activities or those of its suppliers and subcontractors to :
- human rights and fundamental freedoms,
- human health and safety,
- the environment.
The 2023 Group Vigilance Plan is published in Vivendi’s Universal Registration Document.
A group-wide vigilance risk mapping was drawn up. It was created by consolidating the maps of each subsidiary, including Dailymotion. Targeted risk mitigation measures have consequently been determined for each subsidiary.
3. Sustainable Purchasing Policy
As part of its commitments relating to compliance and vigilance matters and corporate social responsibility, Dailymotion implemented a Sustainable Purchasing Policy which presents the principles applicable to purchasing and supply chain activities. Based on the development of ethical and sustainable business relationships and the objective of maintaining a constructive dialogue, it sets out our expectations in ethical, social and environmental matters. For Dailymotion, compliance with this Policy is a substantial condition of our business relationships, and we request our suppliers to formally commit to high ethical standards and to ensure that human rights are protected.
Our Sustainable Purchasing Policy specifically and unequivocally condemns any practices qualified as modern slavery or forced, compulsory or clandestine labor within the meaning of ILO Conventions Nos. 29 and 105.
In a more general manner, it also requires all suppliers/subcontractors to comply with all national and international standards applicable to social issues and human rights in their activities and in particular, they must:
- provide decent working conditions and maintain health and safety standards that are compliant with ILO Convention Nos. 102 and 155;
- establish clear working hours and ensure that their workers are paid for the time they work and that they receive equal pay, as well as breaks and time off;
- ensure that wages paid to their workers are adequate to provide a decent standard of living and to meet basic needs, with due regard given to the general level of wages, the cost of living and social security benefits, and that they are paid regularly and within a reasonable period of time (ILO Convention Nos. 95 and 131);
- respect workers’ freedom of association and collective bargaining rights, or, where locally restricted or prohibited, allow any other forms of representation and free and independent bargaining (ILO Conventions Nos. 87, 98 and 154);
- offer and promote access to training and skills development for workers;
- treat migrant workers fairly and comply with the principles of ILO Convention No. 97.
4. Compliance Program and associated Policies
It is also essential for Dailymotion to ensure we all work in a safe and ethical environment.
Since 2002, the Vivendi Group is committed to its Compliance program that sets out general ethics rules applicable to each and every group employee.
Our Anti-Corruption Code is a core component of this Compliance Program, and any violation of it can be reported internally through a dedicated reporting process or through our whistleblowing online system.
Whistleblowing reports are investigated by a dedicated Investigation Unit which is made up of representatives who are appointed because of their expertise in conducting the necessary investigations, in response to reports submitted through the platform.
A Code of Ethics formalizes a set of ethical principles common to all of the Vivendi Group entities in terms of respect for people, integrity, asset protection and environmental protection.
As such, Dailymotion makes it an essential condition that its own employees and business partners respect these principles.
We deployed a due diligence process applicable to the third parties we intend to work with or already work with, to identify potential risks of corruption, but also potential risks of violation of the main rules and principles in terms of environment, human rights, and health and safety of individuals.
To know more about Dailymotion’s Compliance Program, you can refer to the following URL: https://legal.dailymotion.com/en/compliance/.
III – Risk Assessment and Due diligence Process
Dailymotion has developed, via the policies and processes described above, a risk-based approach that includes a risk assessment of our activities and suppliers over human rights, human safety and environment.
A proper third-party assessment policy has been formalized, establishing criteria based on the risk-mapping, to conduct a due diligence.
Based on the due diligence outcome, Dailymotion may also implement several means to ensure that our suppliers also apply high standards of ethics themselves and ensure that human rights are protected, such as compliance clauses per which the respect of our Sustainable Purchasing Policy, as described above, is an essential condition.
IV – Training
Compliance with vigilance commitments goes through regular trainings and awareness of our own employees.
As such, a Compliance and CSR officer is in charge of deploying the Vigilance program and thus the human rights subjects including modern slavery. For any arrival at Dailymotion, there is a presentation of our Compliance and CSR officer including these matters. Each new Dailymotion employee, upon its arrival, has to follow three mandatory online trainings on these matters :
- Duty of Vigilance ;
- Fight against Harassment ;
- Anticorruption.
These trainings have to be renewed every two years.
They are also obliged to respect our Code of Conduct and our Internal Regulations, and all new joiners receive a global introduction to our Compliance Program and Corporate Social Responsibility Program.
Moreover, employees in charge of purchases or most likely to interact with clients or suppliers, receive specific trainings on anti-corruption, gifts and invitations policies, as well as sustainable and ethical purchases.
V – Communication and indicators
Dailymotion is following several indicators to ensure that its employees are aware and regularly trained on the above-mentioned topics. In 2023, more than 95% of our employees had completed the three e-learning trainings mentioned in the section above. Dailymotion also carefully tracks the number of people trained on our Sustainable Purchasing Policy and associated processes.
Dailymotion follows the number of due diligence done on suppliers and the number of suppliers in each of the risk categories it has established (low, medium, high risk), as well as the number of compliance questionnaires sent and completed by its suppliers, the number of contracts that contains our compliance clause, etc.
We also regularly publish transparency reports notably on how we tackle user reports and illicit content, including those which may have an impact on human rights. Our transparency reports contain both quantitative and qualitative indicators on illicit content, reports, requests from authorities, trusted flaggers, and content protection measures.
Dailymotion integrates tools that identify invalid traffic, measure visibility and detect unsafe environments for brands according to the strictest industry standards.
We aim to constantly improve our commitments to ethical standards and we are developing more formalized processes for sustainable purchases and ethical conduct through 2024.
Approved by representatives of our Board of Directors on July 11, 2024.