Associated Press Television News Limited Modern Slavery Statement

INTRODUCTION AND POLICY STATEMENT

Associated Press Television News Limited (APTN), the UK subsidiary of The Associated Press,
which has its head office in New York (collectively “AP”) is committed to upholding the highest
standards of ethical journalism and responsible business practices.

As a global leader in factual journalism, AP recognises its legal and ethical responsibility to
combat modern slavery in all its forms, both in the way it conducts its business and through the
standards it expects across its operations and supply chains. AP has zero tolerance for modern
slavery, including forced labour and human trafficking, and is committed to operating
responsibly and ethically in all aspects of its business.

This ninth Modern Slavery Statement is published in accordance with the Modern Slavery Act
2015. The purpose of this Statement is to outline AP’s approach to identifying, assessing and
addressing modern slavery risks within its operations, including the responsibilities of those
working for or on behalf of AP.

This statement includes the measures AP has implemented over the past year to combat modern
slavery and outlines the strategic initiatives planned for the next 12 to 18 months to support
continued compliance and strengthen AP’s ethical and responsible business practices.

ABOUT THE AP

AP is an independent global news organisation dedicated to factual and non-partisan reporting. Founded in 1846, AP is a not-for-profit cooperative and one of the world’s most trusted news agencies. According to AP’s 2025 statistics, AP’s network reaches across 220 locations worldwide in 90 countries.

AP’s business operations are organised across three core areas:

AP employs a diverse workforce including full-time staff and freelancers in nearly 100 countries and across all 50 US states, delivering news to an estimated four billion people daily. In addition, AP serves customers in 126 countries, demonstrating the global outreach of AP’s services.

News:

Our global team of editorial leaders oversees all aspects of news production, including specialised coverage in areas such as sports, entertainment, climate, investigative journalism, photography, video, social media, and interactive graphics.

Business Operations:

This includes revenue, corporate finance, legal, human resources and corporate communications. Employees in these departments assist with daily operations of the business, which provides the opportunity to compete in a fast-paced business sector.

Technology:

The technology team is integral to AP’s operations, supporting the production and delivery of news. As one of AP’s largest divisions, it underpins the creation and distribution of content to customers worldwide. This team includes a broad range of experts, including technicians, application developers, security engineers and other technology specialists.

AP works with a broad network of third parties to support the accurate and unbiased news reports to its customers. Often, AP must report from some of the world’s most inaccessible and hostile regions to bring current events to the attention of the world.

AP BUSINESS STRUCTURE

AP’s expansive business structure encompasses news gathering, production and distribution, complemented by various additional service offerings:

AP 360

Offers comprehensive production and editorial solutions through a global network of permanent and temporary facilities. It provides access to state-of-the-art workspaces, production infrastructure, and live reporting capabilities to support end-to-end content creation.

AP Content Services

AP’s content marketing and advertising service collaborates with brands and advertisers worldwide to create and distribute authentic, impactful and informative content through the AP distribution network.

AP Productions

A division of AP that develops a variety of media projects in the form of original short films, documentaries, mini-series, podcasts and scripts. The global team of journalists and researchers provides expert and accurate information.

Planning and Media Tools

Newsgathering and planning tools to support newsroom activity across the world, including AP Playbook, AP Stylebook, AP Daybooks, AP Planner and Metadata tagging.

AP Workflow Solutions

AP’s multimedia content production system utilised by broadcast and digital newsrooms worldwide.

Supporting AP’s revenue sources are its operational and corporate divisions, located at both AP’s headquarters in New York, and at its subsidiary offices, local branches and bureaux around the world.

AP SUPPLY CHAINS

Owing to its global presence, AP recognises that modern slavery risks may vary across the jurisdictions and environments in which it operates. AP therefore seeks to maintain appropriate visibility over the sources and origins of its content, the methods by which content is collected and communicated, and the third parties involved in supporting its operations.

AP’s supply chains encompass:

AP’s newsgathering supply chains are diverse and extensive. Given the complexity of newsgathering supply chains, AP seeks to apply appropriate source checks and editorial safeguards. These supply chains include freelance journalists, UGC content providers, and specialist equipment suppliers.

In breaking news situations, AP must react swiftly and often relies on ad hoc information providers. Whenever possible, AP endeavours to work with known and trusted providers, avoids anonymous sources, and ensures adherence to AP’s Statement of News Values and Principles. In instances where AP lacks an established relationship with a provider, AP seeks to verify that information has been obtained lawfully, ethically and without coercion, and in compliance with the Modern Slavery Act 2015 and applicable modern slavery legislation.

For AP’s comprehensive content licensing and distribution operations, the supply chains include third-party content licensing partners, broadcasting/transmission equipment suppliers and maintenance teams.

AP’s location services and commercial production departments share similar supply chains to those mentioned above, with the addition of local facilities providers around the world, equipment suppliers, transportation services and additional maintenance support.

AP’s software tools and corporate functions rely on its technology partners to provide uninterrupted access to its networks, along with operational support and office maintenance requirements.

AP COMPLIANCE POLICIES AND REPORTING MISCONDUCT

AP’s commitment to ethical conduct is reflected in its Code of Business Conduct and Ethics, which aligns with all relevant legal and ethical standards. Employees who have questions about the Code, or who become aware of potential policy violations, are encouraged to report their concerns without delay. In addition, AP operates a confidential ‘Integrity Hotline’ for reporting suspected violations, which is accessible to employees, vendors and customers worldwide. This hotline provides a secure channel for reporting suspected violations of company policy, law and/or other potentially improper business conduct.

UN Guiding Principles on Business and Human Rights

AP seeks to respect human rights through ethical business practices, responsible sourcing and engagement with suppliers and third parties.

The table below summarises how AP’s existing policies and practices support the principles reflected in the UNGPs:

UNGP PillarPrincipleAP’s Current or Planned Actions:
ProtectThe state’s duty to protect human rightsAP operates in accordance with applicable legislation, including the Modern Slavery Act 2015, and seeks to identify and address modern slavery risks within its operations and supply chains.
RespectBusinesses’ responsibility to respect human rightsAP seeks to respect human rights through ethical business practices, responsible sourcing and engagement with suppliers and third parties.
Remedy Access to remedyAP provides mechanisms for concerns to be raised, reviewed and investigated through established reporting channels.

PREVIOUS RISKS IDENTIFIED AND MONITORING AP’S PROGRESS

AP’s global operations span multiple jurisdictions and involve engagement with a range of suppliers and third parties. AP recognises that modern slavery risks may be heightened in certain territories, particularly where services are delivered through complex or less transparent supply chains.

During previous reviews, AP identified opportunities to strengthen awareness of modern slavery risks and further develop its approach to supply chain risk management. In response, AP has continued to review its existing processes for addressing modern slavery risks in its global operations and has planned initiatives to support a more consistent and risk-based approach to risk management.

Throughout the reporting period, AP developed a department-level supplier risk assessment questionnaire intended to improve understanding of supplier relationships and third-party engagements across the organisation. AP also developed draft awareness materials, including FAQs, training resources and content for a centralised intranet resource hub, designed to support employees in recognising potential indicators of modern slavery and understanding how concerns should be raised and escalated.

These initiatives are intended to strengthen awareness, improve supplier visibility and support the ongoing development of AP’s approach to identifying, assessing and mitigating modern slavery risks across its operations and supply chains.

AP STRATEGIC PLAN:

The table below outlines AP’s strategic actions to address modern slavery risks summarises progress made during the reporting period and identifies key priority actions for the next reporting period.

Action PlanDescriptionProgress to DateNext StepsImpact on Modern Slavery Risk
Review department-
level supplier and
third-party risk
Create an enhanced short checklist for each department to self-assess risks in their external engagements or use of supply chains.AP has developed a structured department-level supplier risk
assessment questionnaire to support teams in identifying risks
associated with third-party engagements. This tool was developed and is being prepared for roll out across relevant departments.
Roll out the questionnaire to relevant teams and analyse responses to identify potential hidden or higher-risk activities.Identifies any hidden risks
Promotes awareness within the organisation
Develop an intranet-based modern slavery resource hubAn action plan for a central and comprehensive resource page is in development, with content aimed at helping staf identify and respond to modern slavery risks.Planning remains in progress on the resource hub.Progress implementation of the resource hub during the next reporting period.Embeds awareness
Strengthens staff knowledge and responsiveness
Increase staff awareness on modern slavery Review and enhance training documents and guidance
materials to ensure modern slavery risks are clearly explained and integrated into compliance training.
Emphasis will be placed on helping staff identify red flags in sourcing, reporting, and supplier interactions.
AP has drafted training and awareness resources to support employees in recognising indicators of modern slavery, understanding reporting processes and identifying
risks within supplier and third-party relationships.
Finalise training materials and
integrate modern slavery awareness
into relevant staff communications
and learning resources.
Improves internal awareness and
supports risk-based due diligence by
equipping staff with practical knowledge.
Expand the scope of due diligence through technology toolsExplore the use of appropriate
technology-enabled tools to strengthen supplier due diligence and risk monitoring.
AP has undertaken an initial review of how technology and existing
internal systems may support supplier due diligence and risk
identification activities.
Assess technology enabled tools and
processes that may strengthen visibility of supplier relationships.
Exposes hidden risks
Monitor effectiveness
and support continuous improvement
AP recognises the importance of
continuously reviewing and
improving its approach to
identifying and managing modern
slavery risks through enhanced visibility, risk assessment and
monitoring activities across its
operations and supply chains.
AP has reviewed its existing approach to monitoring modern
slavery risks and identified opportunities to improve visibility of supplier relationships and operational activities through enhanced risk assessment processes.
Use information gathered through
departmental risk assessments and
awareness initiatives to inform future monitoring activities
and support the development of
meaningful measures of effectiveness.
Supports transparency and
accountability by helping AP monitor risk areas and
assess progress over time.

KPIs AND MONITORING EFFECTIVENESS

AP currently tracks a limited set of quantitative indicators on an ongoing basis. The following metrics have been recorded over the past five years as part of AP’s modern slavery monitoring programme. These indicators provide a baseline for monitoring reported concerns and confirmed incidents, but AP recognises that they do not, on their own, provide a complete measure of modern slavery risk across its operations, suppliers and third-party relationships.

KPI Description2020-20212021-20222022-20232023-20242024-20252025-2026
Number of confirmed modern slavery related incidents requiring formal remediation and corrective actions. 000000
Total number of reports received through the AP Integrity Hotline specifically related to suspected modern slavery or forced labour concerns.000000
Total number of reports received through the AP Integrity Hotline alleging breaches of the AP Code of Business Conduct and Ethics000000

From the next reporting period, AP intends to supplement these incident-based KPIs with process-based measures, including supplier risk assessments, staff awareness activities and supplier due diligence activities. These additional indicators are intended to provide a more meaningful assessment of AP’s efforts to identify, assess and mitigate modern slavery risks across its operations and supply chains.

During this reporting period, AP has begun transitioning towards a more risk-based approach to monitoring effectiveness, supported by supplier risk assessment and awareness initiatives. As these initiatives develop, AP will focus on process-based indicators that support improved risk identification, monitoring and accountability. AP will use information gathered through these indicators to refine its monitoring approach, support continuous improvement and inform the development of more meaningful KPIs in future reporting periods.

AP recognises that addressing modern slavery risks is an ongoing process requiring continued review, awareness and improvement. AP will therefore continue to develop its risk-based approach, strengthen internal awareness and enhance visibility across its supplier and third-party relationships, with the aim of supporting responsible business practices and compliance with the Modern Slavery Act 2015 and applicable modern slavery legislation.

ASSOCIATED PRESS TELEVISION NEWS LTD

This statement has been approved by the Board of Directors of Associated Press Television News Limited on 23 September 2026.

Signed on behalf of the Board
Bridget Forrester

DIRECTOR

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