Legal Notices

Employment and Conduct

Modern Slavery and Human Trafficking

December19 is committed to preventing modern slavery and human trafficking in our business and supply chain. This statement sets out the steps we take to identify and address the risk of modern slavery across our operations, our supplier relationships, and the media supply chain we manage on behalf of clients. See policy.

Anti-Bribery

December19 has a zero-tolerance approach to bribery and corruption. This policy sets out our obligations under the Bribery Act 2010, the standards of conduct we expect from everyone connected with our business, and our procedures for reporting and handling concerns. See policy.

Sexual Harassment

December19 has a zero-tolerance approach to sexual harassment. This policy sets out our commitment to preventing harassment in the workplace, the standards of behaviour we expect from everyone — including third parties — and the steps we will take if concerns are raised. It reflects our obligations under the Worker Protection (Amendment of Equality Act 2010) Act 2023. See policy.

Whistleblowing

December19 encourages anyone who has a genuine concern about wrongdoing, illegal activity, or a serious risk to public interest to speak up. This policy sets out the protections available to whistleblowers, how concerns are handled, and the routes available for raising issues — internally and externally. See policy.

Health and Safety

December19 is committed to providing a safe and healthy working environment for everyone who works at, visits or is affected by our operations. This policy sets out our responsibilities, the arrangements we have in place, and how we manage health and safety across our office and hybrid working arrangements. See policy.

Working Conditions

This policy sets out the core employment principles at December19 — including our commitment to the Real Living Wage, working hours, benefits, wellbeing and equality. It reflects our belief that how we treat our team is inseparable from how we treat our clients and the communities around us. See policy.

Values and Inclusion

Code of Ethics

Our Code of Ethics sets out the values and principles that guide every decision we make — with clients, colleagues, suppliers, the community and the environment. It is the foundation on which all of our other policies sit. See policy.

JEDI Commitment Statement

Justice, equity, diversity and inclusion are central to how we work and how we grow. This statement sets out our public commitment to JEDI, the social identities we have prioritised, the accountability we place on our leadership team, and the actions we are taking - year by year - to become a more representative and inclusive organisation. See statement.

Local & Inclusive Hiring: How we Hire

We’re committed to recruiting fairly, openly, and in a way that gives everyone a genuine opportunity - regardless of background.

In practice, that means:
Blind CV reviewing: where operationally practical, identifying information (name, address, age indicators) is removed before shortlisting to reduce the risk of unconscious bias.
No salary history requests: we set salaries based on the role, not what someone earned before.
Diverse shortlists: we ask recruitment partners to provide longlists that reflect a range of backgrounds and experiences.
Structured interviews: all candidates are assessed against the same objective criteria.
Reasonable adjustments: we’ll make adjustments at any stage of the process; just let us know what you need.
Local hiring: where roles allow, we actively consider candidates from the local community

If you have any questions about our recruitment process or would like to request an adjustment, please contact us at concerns@december19.co.uk.

Equality, Diversity and Inclusion

December19 is committed to creating a workplace where everyone is treated with fairness, dignity and respect. This policy sets out our approach to equality and diversity across recruitment, employment and development - and the steps we take to prevent discrimination, harassment and victimisation. See policy.

Human Rights Due Diligence

This statement sets out December19’s approach to identifying and addressing actual and potential human rights impacts across our operations and supply chain, in line with the UN Guiding Principles on Business and Human Rights. See statement.

Data Protection Policy

December19 takes its obligations under UK GDPR and the Data Protection Act 2018 seriously. This policy sets out how we collect, use, store and protect personal data across our business — covering our team, our clients, our suppliers and anyone who interacts with us. It should be read alongside our Privacy Policy and Data Management & Retention Policy. See policy.

Environmental and Sustainability

Environmental Policy

December 19 recognises that it has a responsibility to the environment beyond legal and regulatory requirements. As a media buying agency, the most significant part of our environmental impact lies not in our office - it lies in the media we buy and the wider supply chain we engage on behalf of our clients. See policy.

Carbon Reduction Plan

Our Carbon Reduction Plan sets out our baseline emissions for 2025 (total 3,371.56 tCO₂e), our reduction targets aligned with the SBTi Corporate Net Zero Standard, and the specific actions we are taking year on year. Signed by David Lucy, Managing Director, May 2026. See plan.

Animal Welfare Policy

Animal welfare matters. As a B Corp, we recognise the importance of addressing animal welfare across business operations and supply chains - even where our direct exposure is limited. See policy.

Community and Supply Chain

Local Purchasing Statement

We believe in using our spending power to support local, independent and minority-owned businesses. This statement sets out our commitment to local purchasing, the principles that guide our supplier choices, and our targets for sourcing close to home. See statement.

Stakeholder Engagement

December19 is committed to meaningful, ongoing engagement with the people and organisations affected by our work - our team, clients, suppliers, community and the environment. This statement sets out how we identify and engage with our key stakeholders and how their feedback shapes our decisions. See statement.

Employee Volunteering

December19 supports our team to give time to causes that matter. This policy sets out our paid volunteering commitment, the types of activity it covers, and how team members can request volunteering time. See policy.

Brand Safety

At December19 we understand that brand safety is more than just protecting a brand from harmful content - it’s about ensuring your message lands in the right place, with the right audience, and in the right context. Our brand safety policy ensures that our clients' ads are only placed in environments that align with their values, building trust and delivering results. See policy.