MODERN SLAVERY STATEMENT

April 2024

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Getty Images has taken, and is continuing to take, to ensure that modern slavery and human trafficking is not taking place within our business or supply chain.

Getty Images is a preeminent global visual content creator and marketplace, offering images, video and music to almost 800,000 customers in nearly every country in the world. Our digital products and services do not involve the usual reporting issues around packaging, manufacturing supply chains and human rights for affiliated suppliers and workers; however, we fully support the aims of the UK’s Modern Slavery Act 2015 and are committed to combatting modern slavery and human trafficking. Our values reflect our commitment to acting ethically and with integrity in all our business relationships.

OUR STRUCTURE, BUSINESS AND SUPPLY CHAINS

As of April 2024, the Getty Images operating group’s parent company is Getty Images, Inc, a US entity with subsidiaries in the UK and around the world. The terms “Getty Images”/ “the Group” as used in this statement, refer collectively to Getty Images, Inc. and its subsidiaries, including Getty Images International U.C., Getty Images (UK) Limited and Getty Images UK DevCo Limited as located in Dublin and London respectively. The Group has approximately 1701 employees, with an additional 585 contracted workers and operates on a global basis - employing 110 staff photographers and videographers worldwide and working with over 557,000 independent contributors.

Getty Images is among the world’s leading creators and distributors of award-winning still imagery, video, music, and multimedia products. The Group has numerous sources for the imagery and digital content we license to our customers throughout the world as via our websites in over 23 different languages, such content ranging from wholly owned content created by our staff photographers to content created/owned by our network of contributors, to content distributed through partnerships with photographic and video agencies and other large media companies. In addition, we have vendor relationships with suppliers for facilities, technology, financial services and the provision of benefits for our employees.

OUR POLICIES

We have adopted Codes of Conduct which set out the principles by which we conduct our business and with which we expect all employees, vendors, contributors and business partners to comply with. Our Code of Ethics, Code of Business Conduct and Contributor Code of Conduct, (“Codes of Conduct”), as annually reviewed by our global legal team, set out the terms and conditions as required by law to provide a work culture that promotes equality, diversity, inclusion and respect in the workplace and allows for whistleblowing and other processes for raising grievances or concerns in the workplace. It is mandatory for all our employees to confirm that they have read and understood Getty Images’ Codes of Conduct as relevant to them and to undertake yearly refreshers in such codes. Any failure to comply with the provisions of our Codes of Conduct may result in disciplinary action or termination of employment.

At Getty Images we consider it integral to our business to operate in an honest, trustworthy and transparent manner as set out in the Getty Images’ Leadership Principles, and in 2024 we continue as always to extend this approach in our relationships with business partners and vendors. We encourage and promote open and frank communication across our supply chains to ensure compliance with our Codes of Conduct, polices, principles or applicable laws. On notification of non-compliance, Getty Images acts appropriately and proportionately to bring a solution to allow for corrective action or if necessary, terminatation of an agreement. Such termination will occur if a supplier is not adhering to contractual obligations or there is a blatant disregard for our polices or Codes of Conduct. Additionally, Getty Images shall if warranted, report that supplier to the appropriate regulating authority.

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

Whilst we still have not identified modern slavery as being a particular risk in our own business and supply chains, as part of our ongoing initiative to identify and mitigate risk we:

• Audit our HR files to ensure we have the correct right to work information for all employees and are in compliance with local requirements in territories outside of the UK;
• Include provisions within our due diligence questionnaires and terms of business with our suppliers, which require compliance with all applicable laws, including modern slavery;
• Continue to review our supplier audit program to include modern slavery;
• Collaborate with vendors and customers across internal functions and responding to their own due diligence processes;
• Protect whistle-blowers and deploy a dedicated whistleblowing hotline as well as a dedicated employee page for raising any concerns (which has been updated in 2024 to include an explicit reporting option for human-trafficking);  and
• Routinely review our content as to vulnerable persons to ensure its compliance with our strict content policy guidelines as well as legal standards.

Regarding our large suppliers or those operating in a high-risk territory/industry for modern slavery or human trafficking we have taken active steps to risk assess their business and ensure compliance with our principles. Getty Images continues to apply resources to monitor these supplier relationships and demonstrate vigilance. Our Group has always taken the welfare of its contracted workers hired via an external supplier very seriously and in addition to the audit of a supplier’s performance Getty Images undertakes a review of the welfare and benefits packages offered by that supplier to its workers. We continue to engage with our third party contracted workers located on site to ensure their well-being and offer open communication to raise concerns as to their working conditions or terms of contract.

Within Getty Images’ own production, distribution, and supply of services we proactively manage and control the Group’s international working conditions in relation to hours of labour, pay rates and environment to ensure there is limited risk of modern slavery within our own business.

At Getty Images we are proud of our editorial integrity in delivering unbiased content objectively capturing global current events. Although we consider our digital content products and services to be low risk of non-compliance with the Modern Slavery Act, our continual audit and review of our supply chain allows us as a Group to operate responsibly, accounting for our business and supply chain to deliver with confidence digital content to our global customers. Getty Images continues to share and make available to its global contributors its ‘Contributor Code of Conduct’, emphasising our commitment to provide an environment where any people creating a shoot, including contributor’s employees, editors and models are treated fairly, with respect and free from unlawful discrimination or treatment. In addition, we provide our contributors with a whistle-blower hotline for any persons associated with a photography shoot that may have experienced, witnessed or know of conduct that falls short of Getty Images’ standards.

MEASURING EFFECTIVENESS

We shall annually review our global practices, processes and procedures in relation to the Group’s business operations and supplier engagement to ensure mitigation of risk of non‐compliance with the Modern Slavery Act. Getty Images continues to encourage conversations between key stakeholders to highlight and discover areas of risk as to Modern Slavery in our business.

TRAINING

We continue to promote our Leadership Principles of transparency, fairness and integrity in everything we do. To maintain these principles as part of the Getty Images onboarding process, alongside other compliance training, new employees are made aware of Modern Slavery, our due diligence polices and reporting procedures pertaining to modern slavery in our business and/or supply chain or any other derogatory or inhumane treatment they may become aware of across our Group or services. We train all employees on an ongoing basis, including training on Getty Images’ Leadership Principles and our Codes of Conduct, which are readily available for employees and contractors to access. Each year Getty Images provides updated materials for employees on the Group’s whistleblowing policies and harassment in the workplace training – reminding each member of staff what may constitute as harmful /prejudicial treatment relating to a person’s race, gender, age, physical ability or any other characteristic. In general, and specific to Modern Slavery, we continuously seek to improve risk identification across the Group targeting employees who deal with suppliers as part of their day to day.

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes the Group’s slavery and human trafficking statement for the financial year ending 31 December 2023 as applicable to 2024.

This statement has been approved by:

Craig Peters
CEO
GETTY IMAGES