Modern Slavery & Human Trafficking Policy



Modern Slavery & Human Trafficking Policy

Contents

|Policy Statement |Page 3 |

|Our Position on Modern Slavery and Human Trafficking | |

|Commitments |Page 4 |

|Modern Slavery Policy |Page 5 |

|Relevant Policies |Page 6 |

|Compliance with the Policy |Page 7 |

|Breach of the Policy | |

|Amendments to the Policy |Page 8 |

|Board Member Approval | |

|Acceptance of the Policy | |

|Appendix 1 - Procurement & Corporate Responsibility Code of Conduct for Suppliers |Page 9 |

Policy Statement

This statement sets out the actions of the Company to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at making sure there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 15 January 2018 and 14 January 2019.

As part of the leisure sector, the Company recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

Our Company is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Please note that any breach of this policy will be taken seriously and may result in disciplinary action.

Our Position on Modern Slavery and Human Trafficking

We take the issue of modern slavery and human trafficking extremely seriously and prohibit all forms of slavery in both our own Company and our supply chains.

Industries that are particularly at risk of modern slavery are labour intensive and characterised by a high proportion of migrant workers undertaking unskilled and irregular work, often supplied through recruitment intermediaries.

We’re committed to applying our Equal Opportunities Policy at all stages of recruitment and selection, and we’ll avoid unlawful discrimination in all aspects of employment. All terms and conditions of employment are the same in all jobs of equal value as is the company equality policy. We make sure all our internal colleagues go through the same robust process for recruitment and training irrespective of how colleagues are recruited.

We are an entertainment business with skilled colleagues, due to the technical and highly regulated nature of our offering, and have a relatively small supply chain compared to other retail businesses.

We also work with a number of key suppliers, who provide products and services across a number of different areas, including, technology, software and telecoms, professional services, leisure products, property and premises and marketing and data rights. We do have suppliers for other products such as food and beverage, uniform, cleaning and janitorial materials, merchandise etc. to make sure our entertainment package can be delivered.

We’re aware that certain products that we purchase from our suppliers may be sourced or manufactured from outside of the UK and have put in place certain steps and processes with our suppliers to prevent modern slavery to which we believe our business to be low risk due to the robust recruitment, training and skills required from our colleagues, and specific standards expected from all suppliers.

Relevant Policies

Our HR policies are fully compliant with the Equality Act 2010. The Company operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations. The list of relevant policies is detailed below and further information regarding these can be found within the Modern Slavery and Human Trafficking Policy, also within individual procedure and policies.

• Whistleblowing policy 

• Colleague Code of Conduct

• Supplier/Procurement Code of Conduct  

• Recruitment/Agency workers policy 

• Due diligence

Commitments

• We’re committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.

• All our supplier contracts warrant that they comply with the Modern Slavery Act, and set out the minimum standards required to combat modern slavery and trafficking.

• We are taking a risk based approach as part of our supplier due diligence processes by ensuring that they have adopted a satisfactory approach to modern slavery and shall keep them under review.

• We will assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties.

• Consistent with our risk-based approach, we require employment and recruitment agencies and other third parties supplying workers to our Company to confirm their compliance with our Policy.

• As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance following their responses.

• If we find that other individuals or Company’s working on our behalf have breached this policy, we will make sure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.

Modern Slavery Policy

Introduction

Our Company is committed to making sure there is transparency within our own business and in our approach to tackling Modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. Our moral and legal obligations are for the safety of all our colleagues, suppliers, contractors and customers.

We take the responsibility of modern slavery and human trafficking very seriously. It is a crime and violation of human rights, which takes various forms such as slavery, servitude, forced and compulsory labour and human trafficking. All of which have in common the deprivation of another person’s liberty by another, in order to exploit them for personal or commercial gain.

We have a zero-tolerance approach to modern slavery and we are committed to acting ethically with integrity in all our business dealings and relationships and are committed to implementing and enforcing effective systems and controls to make sure modern slavery is not taking place anywhere within our business or in any of our supply chains.

We ensure that all our colleagues are not exploited and are paid at or above the National Minimum Wage or the National Living Wage, with relevant training and within a safe working environment. All colleagues are given the company handbook on commencement of their contract.

We work with our supply chains to ensure they also take the responsibility to protect their colleagues and contractors to help ensure no one within their chain is being exploited to help combat modern slavery.

We want all our colleagues to have a positive experience working with us. We do not want our colleagues to feel harassed, discriminated against, bullied or coerced. At no time should they be asked for gifts or money for working with us.

Definition of Slavery and Servitude

Slavery, in accordance with the 1926 Slavery Convention, is the status or condition of a person over whom all or powers attaching to the right ownership are exercised. Since legal ownership of a person is not possible, the key element of slavery is the behaviour on the part of the offender as he/she did own the person, which deprives the victim of their freedom.

Servitude is the obligation to provide services that are imposed using coercion. This includes the obligation to provide services that are imposed by the use of coercion, the obligation for a serf to live on another person’s property and the impossibility of changing his or her condition.

Definition of Human Trafficking

An offence of human trafficking requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. The offence can be committed even when the victim consents to the travel. This reflects the fact that the victim may be deceived by the promise of a better life or a job or maybe a child who is influenced to travel by an adult. In addition, the exploitation of the potential victim does not need to have taken place for the offence to be committed. It means that the arranging or facilitating the movement of the individual was with a view to exploiting them to sexual or non-sexual exploitation.

Relevant Policies

Our HR policies are fully compliant with the Equality Act 2010.

Whistleblowing Policy

Our Company encourages all our colleagues, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Colleagues who have concerns should raise these with their Line Manager in the first instance, or can use our confidential helpline via SeeHearSpeakUp, which is available 24 hours a day operated by trained personnel 7 days a week on 0800 988 6818. Alternatively, colleagues can report via the webpage seehearspeakup.co.uk.

Colleague code of conduct

The Company's code outlines the actions and behaviour expected of all colleagues when representing the Company. The Company strives to maintain the highest standards of colleague conduct and ethical behaviour and when managing its supply chain.

Supplier/Procurement code of conduct

Our Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Company works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the Company's supplier code of conduct (Appendix 1) will lead to the termination of the business relationship.

Recruitment/Agency workers policy

Our Company only uses specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency, who undertake the same training as internal recruited colleagues.

Due diligence

Internally, we have several processes in place to verify the identity of our colleagues to make sure we know exactly who is part of our teams. All our colleagues undergo identity and right to work checks, before they are offered a contract with us. This is audited as part of our internal audit process. We also carry out reference checks, as appropriate qualifications, CRB and license checking are dependent on certain roles.

Equality and Harassment

It’s against our Company policy for any colleague (or third party) to harass or bully another colleague, relative or customer in any way. We have various ways of dealing with alleged instances of harassment or bullying, as outlined in our Colleague Handbook. We’re also committed to giving people equal opportunities and our policies are designed so that all colleagues are treated fair and equally. We ensure this happens by applying our Equal Opportunities at all stages of our recruitment and selection process and we avoid any unlawful discrimination in all aspect of employment.

Communication

Our Company has a confidential whistleblowing option for colleagues to report any concerns they have in respect of wrongdoing within our Company.

This policy will be communicated to all new colleagues within their induction period as well as display posters for our colleagues to see on a regular basis.

Compliance with the Policy

You must make sure that you read, understand and comply with this policy.

We have zero-tolerance approach to modern slavery in our Company and our supply chains.

The prevention, detection and reporting of modern slavery in any part of our Company or supply chain is the responsibility of all those working for us or on our behalf. Colleagues, representatives and suppliers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.

We encourage everyone to raise concerns about any issue or suspicion in any parts of our business or supply chains of any suppliers.

If there has been a breach or conflict of this policy or you are unsure whether a particular act, the treatment of colleagues more generally, or their working conditions within any tier of our supply chains, constitutes any form of modern slavery or human trafficking, please contact your line manager in the first instance, who will contact our Director of Risk and Compliance. Other support lines are as follows: Modern Slavery helpline 08000 121 700 or our Whistleblowing Company, as listed within this statement.

If you believe anyone to be in immediate danger, call 999 and communicate with your Line Manager or Hayley Jane Lee, our Director of Risk and Compliance on 07767 301182.

Breaches of the Policy

Any colleague found in breach of this policy will be subject to disciplinary action for gross misconduct under the company’s disciplinary policy, which may include disciplinary action up to and including dismissal.

We may terminate our relationship with other individuals, organisations and suppliers if they are found in breach of this policy.

Amendments to the Policy

This policy does not form part of the colleagues Particulars of Terms of Employment and maybe varied from time to time. As a minimum, the statement may change annually to reflect actions taken within the financial year. This will be published on our corporate website.

Board Member Approval

This Statement has been approved by all the Board Members and reviewed by the Company’s Risk & Compliance Director, Procurement Director, Human Resources Director and Chief Executive Officer, who will review and update the statement annually.

Appendix 1 - Procurement & Corporate Responsibility Code of Conduct for Suppliers

Code of Conduct

We’re increasingly aware and concerned about the potential environmental and social cost that may occur as a result of organisations in our supply chain behaving in an unethical manner. We’re also rightly concerned about the reputational damage that may occur to the Company, our customers and partners, so we have developed a code of conduct for procurement and corporate responsibility (the “Code”). The code sets out our commitment to doing the right thing within the supply chain and acting with integrity.

We expect our business partners and suppliers (“Suppliers”) to adhere to the principles of the Code wherever they operate around the world. We will engage with our Suppliers to manage the social and environmental impacts of the products and services we procure, paying attention to what we use and the origin of what we use is critical to reducing our environmental impact.

We will ensure that the goods and services we purchase are considered for their environmental impact. Suppliers will share our commitment to doing the right thing and acting with integrity and will operate in a way that is consistent with the Code. As an ethical operator, the Company believes in the fair treatment of its workforce and we aim to source our products and services from Suppliers that also employ fair working practices and utilise ethical policies and practices throughout their own procurement and production. The Company is acutely aware of our impact upon the environment, and our environmental stewardship approach is based on reducing carbon dioxide emissions and understanding and then reducing the impact on the environment of the resources we use. We aim to achieve this through ethical and sustainable procurement, efficient operating and responsible waste strategies, and we aim to reduce our impact on the environment on a year on year basis.

We require that our Suppliers join us in our efforts to reduce our environmental footprint. We will increasingly focus on the environmental behaviour of our supply chain and demand greater environmental responsibility, transparency and efforts in ensuring sustainability. The Supplier confirms that it has a set of business principles consistent with the Code, that it applies across its company including subsidiaries and any third parties it uses to provide goods and services to the Company which establishes the minimum standards to which the Supplier will operate. Such business principles include a commitment to operate with professionalism and integrity and to manage the social and environmental impact of the Suppliers business.

Operating Safely and Securely

The Supplier confirms that it has a robust health and safety management system in place covering matters that include but are not limited to:

• Policy;

• Board level accountability;

• Risk identification and mitigation;

• Competency & training;

• Measuring and reporting; and

• Periodic performance review.

Conducting Business with Integrity

The Supplier confirms that:

• It has and will comply with all relevant and applicable anti-bribery and corruption legislation;

• It has in place anti-bribery and corruption policies and procedures that apply across its business and subsidiaries;

• The policy prohibits bribes of any form as described above, including kickback payments and facilitation payments;

• It has not and will not use gifts or donations to influence a decision or create an improper advantage;

• It will not, in its relationship with the Company (including its employees and contractors), offer gifts, hospitality or donations or seek to obtain an improper business advantage with gifts, hospitality or donations; and

• It is compliant with other legal and regulatory rules and standards, specifically in relation to fraud, and will not tolerate or accept any such behaviour from its suppliers.

The Supplier also confirms that it will compete fairly, and this includes:

• Not using or passing insider information for their own or another’s benefit;

• Dealing with consumers and business partners in a fair, ethical and transparent way and not engage in anti-competitive activity;

• Extending, where possible, positive social and environmental impacts beyond its own operations; and

• Being fair, ethical and transparent in its communications and dealings with its own business partners and other stakeholders affected by its supply chain activities including taking reasonable steps to ensure that it fulfils the payment terms and other conditions agreed with its business partners.

Valuing People & Human Rights

The Supplier confirms that (unless otherwise required or prohibited by law):

• It will recruit people on the basis of the qualifications and individual capabilities needed to do the job;

• It will embrace diversity and not operate any form of discrimination, harassment or bullying in the workplace;

• It will offer fair rewards and recognitions;

• It does not discriminate against any employees on any grounds (including, but not limited to, age, race, religion, disability or gender);

• It does not engage in or support the use of corporate punishment, mental, physical, sexual or verbal abuse and does not use cruel or abusive disciplinary procedures in the workplace;

• It pays each employee at least the minimum wage, or a fair representation of the prevailing industry wage, (whichever is the higher) which allows the employee to sustain the essentials for quality life;

• It provides each employee with all legally mandated benefits;

• It complies with the laws on working hours and employment rights in the countries in which it operates;

• It is respectful of its employees’ rights to join and form independent trade unions and freedom of association;

• It has taken all appropriate steps to ensure there are no Modern Slavery Practices in its supply chain;

• It provides a safe and healthy workplace, presenting no immediate hazards to its employees;

• Any housing provided by the Supplier for its employees is safe and fit for habitation; and

• It provides access to clean water, food & emergency healthcare to its employees in the event of accidents or incidents in the Suppliers workplace.

Valuing the Community

The Supplier confirms that it manages its social and economic impact on local stakeholders and communities. Where the Suppliers activities may have a negative impact on local stakeholders and communities, the Supplier confirms that:

• It has a policy to outline how it manages its social and economic impact on local stakeholders and communities; and

• Such policy outlines:

o When the Supplier will conduct impact assessments;

o Who the Supplier will allow to participate in impact assessments; and

o Where, when and how the impact assessments will be made available.

Valuing the Environment

The Supplier confirms that it understands, manages and reduces its own environmental impact and where possible, will help the Company to meet its environmental goals. With this in mind, the Supplier confirms that that it has a robust environmental management process in place including but not limited to:

• Policy which includes a commitment to reduce its impact on the environment including:

o CO2 and energy management with reduction targets; and

o Waste management and recycling;

• Board level accountability;

• Impact and risk identification and mitigation;

• Competency & training;

• Measuring and reporting; and

• Periodic performance review.

We will monitor performance and take appropriate action where we believe Suppliers do not act consistently with our standards. The Supplier confirms that it will be responsive to any concerns raised by the Company about the Suppliers own supply chain raised by stakeholders or by business partners through the Company’s procurement and supplier management processes. The Company reserves the right to, either before or after we begin to work with a Supplier, to appoint our nominated ethical supply chain auditor to conduct an analysis of the policies, procedures and processes in place at the Supplier. If there are significant deviations to our Code and standards then we will not engage with that Supplier.

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