Human Rights
Due Diligence
Our commitment
December19 is committed to respecting internationally recognised human rights across all of our business activities and relationships. We support the principles set out in the UN Guiding Principles on Business and Human Rights (UNGPs), the International Bill of Human Rights, and the ILO Declaration on Fundamental Principles and Rights at Work.
Our approach to due diligence
As a media buying agency, our most significant human rights touchpoints relate to the people in our team, the supply chains of the media owners and platforms we buy from, and the nature of the clients we choose to work with. We have identified four areas of material risk:
Labour rights in the digital media supply chain: programmatic and digital advertising involves multiple intermediaries including ad tech platforms, data processors and offshore operations whose labour practices we cannot directly observe. We work with media partners that are signatories to recognised industry standards, apply our Supplier Screening Questionnaire to significant suppliers, and support the Conscious Advertising Network on supply chain ethics.
Client screening: we do not accept clients whose primary business causes material harm to people or communities. We review new client relationships at onboarding against our FCA Register Onboarding Policy and broader ethical criteria, and reserve the right to exit relationships that conflict with our values.
Fair work in our own operations: we pay the Real Living Wage as a minimum, publish our Working Conditions Policy, operate a JEDI programme with annual diversity monitoring and pay gap analysis, and hold ourselves accountable through B Corp recertification.
Supplier due diligence: we screen new suppliers through our Supplier Screening Questionnaire, which covers environmental, social, governance and ethical criteria. We prioritise B Corp certified and independently verified suppliers where quality and value allow, and maintain a Sustainable & Preferred Suppliers Guide to support consistent purchasing decisions.
Reporting concerns
Anyone with a concern about how December19 is meeting its human rights commitments can raise it through our Complaints and Concerns process at december19.co.uk/complaintsandconcerns.
Review
This statement is reviewed annually by the Managing Director and Managing Partner (Finance). It was last reviewed in June 2026.
Data controller: December 19 Limited
Registered office: Clerkenwell Workshops, CS.112, 27–31 Clerkenwell Close, London, EC1R 0AT
Contact: hello@december19.co.uk
Version: 1.0
Last updated: 16.06.26