SDI Policies and Values

Diversity, Equity and Inclusion Policy  |  Modern Slavery Act Transparency Statement  |     Privacy Policy Related to GDPR

Equal Opportunities and Commitment Against Discrimination

SDI Media is an equal opportunities employer committed to providing equal opportunities throughout employment including, but not limited to, recruitment, selection, placement, training, compensation, promotion, transfer and termination of employment. The Company’s objective is to attract job applications and applications for promotion and training from the best possible candidates and to recruit and promote individuals on the basis of merit, regardless of any other grounds.

SDI Media prohibits discrimination based on any of the characteristics protected by federal and/or state law, including, but not limited to, sex, sexual orientation or identity, gender, race, color, religion, belief, national or ethnic origin, creed, citizenship status, ancestry, age, marital status, parental status, part-time status, pregnancy, childbirth or related medical condition, medical condition including genetic characteristics, mental or physical disability, veteran status or any other characteristic protected by federal, state, or local law, ordinance or regulation. SDI Media welcomes and makes reasonable accommodations for disabled employees. We have clearly defined and well-communicated policies that prohibit all forms of harassment and discrimination. Through regular prevention and awareness trainings, we ensure each and every employee and manager not only understand the policy and subject matter, but openly discuss and exchange upon applicable examples related to our day to day work environment.

We regularly and clearly communicate our independent portal where employees and/or external partners of SDI Media can report concerns, whether involving a workplace issue, suspected illegal or unethical conduct, or any other matter, without fear of retaliation ( Whistle-Blower Hotline Phone: +1 310 388 4209). SDI Media ensures all employees, contractors and freelancers have agreed on the terms and conditions of their engagement with SDI Media. SDI Media ensures that modern slavery, human trafficking or forced labor is not taking place within our business or supply chain (see Modern Slavery Act Statement below).

SDI Media’s Board of Directors oversee our efforts to combat harassment and discrimination of all forms through oversite of our polices and regular risk assessments. Everyone who works for SDI Media has a responsibility to ensure that our policies and commitments against discrimination are observed and carried out within our regular practices and daily behaviors at all times.

Diversity, Equity and Inclusion Policy 

SDI Media is committed to fostering, cultivating and preserving a culture of diversity, equity and inclusion. Our human capital is the most valuable asset we have. The collective sum of the individual differences, life experiences, knowledge, inventiveness, innovation, self-expression, unique capabilities and talent that our employees invest in their work represents a significant part of not only our culture, but our reputation and company’s achievement as well.

We embrace and encourage our employees’ differences in age, color, disability, ethnicity, family or marital status, gender identity or expression, language, national origin, physical and mental ability, political affiliation, race, religion, sexual orientation, socio-economic status, veteran status, and other characteristics that make our employees unique. SDI Media diversity initiatives are applicable—but not limited—to our practices and policies on recruitment and selection; compensation and benefits; professional development and training; promotions; transfers; social and recreational programs; layoffs; terminations; and the ongoing development of a work environment built on the premise of gender and diversity equity that encourages and enforces:

  • Respectful communication and cooperation between all employees.
  • Teamwork and employee participation, permitting the representation of all groups and employee perspectives.
  • Work/life balance through flexible work schedules to accommodate employees’ varying needs.
  • Employer and employee contributions to the communities we serve to promote a greater understanding and respect for the diversity.

All employees of SDI Media have a responsibility to treat others with dignity and respect at all times. All employees are expected to exhibit conduct that reflects inclusion during work, at work functions on or off the work site, and at all other company-sponsored and participative events. All employees are also required to attend and complete annual diversity awareness training to enhance their knowledge to fulfill this responsibility. Any employee found to have exhibited any inappropriate conduct or behavior against others may be subject to disciplinary action. Employees who believe they have been subjected to any kind of discrimination that conflicts with the company’s diversity policy and initiatives should seek assistance from a supervisor or an HR representative.

Modern Slavery Act Transparency Statement

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

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. SDI Media has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our Business – SDI Media is the leading provider of dubbing, subtitling, translation and media services to the world’s most recognizable entertainment companies. Its network of owned and operated studios in 29 countries forms the largest and most accessible one-stop media localization solution for distribution to any window, anywhere. SDI Media specializes in cost effective services, using proprietary technology and supported by operational hubs in Los Angeles, Manila and Warsaw.

Our Practices and Policies – We have a number of internal practices and policies employees must abide by to ensure that we are conducting business in an ethical and transparent manner. These include:

  1. Modern Slavery Act Statement. This statement is board approved and is located on our company’s website and internal intranet. In addition, all staff are informed via the Employee Handbook, and are aware and educated via annual compliance trainings on our commitment to prevent modern slavery and human trafficking to ensure it is not taking place within our business or supply chain.
  2. Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
  3. Anti-Corruption Policy. All Company personnel, including officers, directors, employees, consultants, agents, and other business partners acting on the Company’s behalf are expected to conduct Company business legally and ethically.This Policy prohibits all Company personnel from providing, offering, proposing, promising, or authorizing the payment of any bribe, kickback, or other improper inducement to any person for the purpose of influencing sales, obtaining or retaining any business opportunity, or otherwise securing any other kind of favourable treatment or business advantage, thus preventing the use of services from any non-legally validated workforce.
  4. Recruitment Practices. We operate robust recruitment practices including conducting eligibility checks to ensure all employees have work permits in the respective country of their work to safeguard against human trafficking or individuals being forced to work against their will.

Our performance indicators – We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if no reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

Approval for this statement – This statement was approved by the Board of Directors on November 15, 2017, updated 20 August 2020.  Click the links below to view previous SDI Media Modern Slavery Act Transparency Statements.

 SDI Media Modern Slavery Act Transparency Statement 2016/2017  

SDI Media Modern Slavery Act Transparency Statement  2019/2020

Privacy Policy Related to General Data Protection Regulations

1 Introduction
We recognise that any personally identifiable information (or personal data) is not our data to use as we wish, but it is data that we are merely custodians of and must be managed in accordance with the General Data Protection Regulation. This policy describes the actions we take to ensure compliance with the policy.
This privacy policy will inform you as to how we look after personal data necessary to provide services when one contacts us or visits our website (regardless of where it is visited from).

This policy ensures we:
• comply with data protection law and follow sound practice
• respect the rights of website visitors
• are open about the way we process and manage information
• reduce the risk of a data breach
• are able to respond quickly in the event of a breach

2 Why we hold data?
We hold personal data and sensitive personal data to enable us to:
• fulfil our contractual obligations
• to comply with legal obligations
• communicate and respond to on-line enquiries

3 Types of Data We Collect From our Website and Email Contacts
Email
If you should use our posted email address to contact us, in order to respond to you we will keep a record of your contact information and correspondence while respecting all aspects of the GDPR.

Cookies
All our internal systems may make use of cookies; a small piece of data sent from our website and stored on the user’s computer by the web browser used. On your first visit it will give you the option to accept cookies or not.

Online Enquiry Forms
• Any collection of personal data arising from your submission of enquiry forms on this website will only be used for the purpose stated on the form e.g. employment enquiries. It is stored for a short time on our secure website content management system. Once contact with enquirer has been initiated, the completed form and any information contained on the form will be permanently deleted. Your data will only be passed securely to the relevant internal team. We are happy to provide, upon request, information on how your data is processed and stored once forwarded internally.
• Information collected via our online enquiry forms are not retained or used for mailing / newsletter purposes.

4 What basis do we hold and process data?
We will only use personal data for lawful business purposes set out under the GDPR (Article 6 Paragraph.1).
It will not always be necessary to obtain consent to hold and process data when it is required for contractual purposes.
We will only hold and process data on the basis that we have explained; we will not seek to process data in a way which is different from the original intent.

5 Individuals Rights
To request to review data that we hold (Article 15 GDPR), to change data that we hold (Article 16 GDPR), to request deletion of data that we hold (Article 17 GDPR), to request the restriction of the data that we hold (Article 18 GDPR), to object to wrong data usage (Article 21 GDPR) or to request a transfer of data that we hold (Article 20 GDPR), or to reclaim the authorization of data usage, you have the right to contact privacy@sdimedia.com.We aim to acknowledge receipt of all requests for data within 24 hours and to fulfil the request according to standards out under the GDPR.
You have the right to report complaints to the local authorities (Article 77 GDPR) if the usage of the personal data is not of originally authorized use.

6 Data Management
6.1 Minimisation of Data
We will hold the minimum amount of data that is necessary for the function of our business.
6.2 Accuracy
We will keep information up to date to the best of our knowledge and correct any inaccurate data that is identified.
6.3 Retention of Data
We will only retain personal data for as long as reasonably necessary in accordance with to local laws to fulfil the purposes we collected it for, including for the purposes of satisfying any job applications, legal, regulatory, tax, accounting or reporting requirements. We may retain personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with the data subject.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of personal data, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
6.4 Transferring Data Overseas
We will not export data overseas without ensuring appropriate data protection arrangements are in place.

7 Protective Measures
7.1 Security of Data
We will ensure that we apply appropriate industry standard security measures when securing and handling personal data.
We will take specialist advice, where necessary, to ensure our security measures are providing the expected level of protection.
7.2 Incident Reporting
We will treat all security incidents as a serious matter and provide appropriate resources to their investigation.
We will report security incidents as required under GDPR and the relevant Data Protection Authority
Employees and direct contractors are required to report any incidents or breaches of this policy as soon as possible.
Any findings as a result of a security incident will be used to improve our systems, processes, and training.
7.3 New Systems and Processes
We will ensure privacy is considered at the outset of any new information processing systems and business processes.
7.4 Third Parties We Work With
Depending on the type of supplier, we undertake one of the following:
• We will review their terms and conditions to ensure they protect data in accordance with GDPR requirements, or
• We will provide details of the information we hold and process, ensure they understand their responsibilities in helping us secure it and formally agree the arrangements.

8 Complaints
We will investigate complaints or disputes concerning the holding or processing of personal data promptly. Contact privacy@sdimedia.com

9 Compliance
9.1 Failures
Failure to comply with this policy by employees will be dealt with under our disciplinary procedures.
Failure to comply with this policy by direct contractors will be dealt with under the terms of the contract between us, which could include termination.
9.2 Training
As part of our regular compliance training, we will train our employees on GDPR and our Privacy Policy.