The Football Association Premier League Limited (“we” or “our”) is committed to the highest standards of professionalism, ethical behaviour and integrity in everything we do and to contributing to the wellbeing of communities around the world.
This is our seventh statement on the anti-slavery and human trafficking measures implemented across our business and is made pursuant to section 54(1) of the Modern Slavery Act 2015.
We are the organising body of the competition currently known as the Premier League (the "Competition"), with responsibility for its Rule Book and the centralised broadcast and other commercial rights. The Competition is the leading professional football league competition in England. It was formed on 20 February 1992 and has been the top division of the professional football league in England since Season 1992/93.
We are structured as a private company that is wholly owned by its 20 member clubs who make up the Competition at any one time (“Clubs”). Each Club holds one share, as well as one special share which is held by the Football Association. Each Club is independent, working within the rules of football, as defined by the Rule Book, The Football Association, UEFA and FIFA, as well being subject to English and European law.
We work proactively and constructively with the Clubs and other football authorities to improve the quality of football, both in England and across the world. Our core values see us aim to be ambitious, inspiring, connected and fair. Our values influence the way we think, communicate, and behave as an organisation and govern the interaction we have with the world around us. Our commitment to conduct our business in an ethical and lawful manner is set out in our Statement of Principles which is available on our website via the following link: https://www.premierleague.com/about/statement-of-principles
Our Supply Chains
Our supply chains consist primarily of service providers whose employees have qualifications and skills that are unlikely to be exploited through forced labour. We assess the risk of modern slavery and human trafficking occurring in our business to be low, but we recognise that no organisation can consider itself immune or afford to be complacent.
Our supply chains include third party suppliers of products and services for our commercial, broadcasting, youth development and football administration operations. These include, amongst others, suppliers of the following products and services:
- Audio-visual equipment/service
- Broadcasting services
- Catering products and services
- Consultancy services
- Educational services
- Financial services
- Food and beverages
- Football operations
- Insurance services
- IT equipment/software/hardware services
- Maintenance services
- Marketing/advertising/design services
- Professional services
- Property management services
- Recruitment services
- Security services
- Supplies for our offices and other sundries
- Training services
- Travel and accommodation services
Anti-Slavery and Human Trafficking Policy
We do not tolerate modern slavery or human trafficking in our organisation or in our supply chain. We comply with all applicable labour laws relating to working terms and conditions, including pay, and we place great emphasis on the fair and equal treatment of all our staff. All our staff (including agency workers) are paid at least the London Living Wage.
Our Anti-Slavery and Human Trafficking Policy (the “Policy”) makes clear our zero-tolerance approach to modern slavery and human trafficking. It shows our commitment to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place anywhere in our own business or in any of our supply chains. The Board of Directors has overall responsibility for ensuring the Policy complies with our legal and ethical obligations, and that all those under our control comply with it.
We provide training to staff on the Policy and on the risk that the business faces from modern slavery and human trafficking in its supply chains. Our staff are required to periodically complete an interactive online learning module which provides context as to how the crimes of modern slavery and human trafficking may be committed. This module was completed by all staff in September 2021 to refresh their learning and understanding. This module also highlights potential warning signs for individuals to be aware of. This module forms part of our induction process for all new employees.
In order to support and bolster the effectiveness of the Policy and the accompanying training, we have in place a whistleblowing hotline and web-based reporting service (“Whistleblowing Service”). While we actively encourage a culture of openness within our business, the Whistleblowing Service (as accompanied by a bespoke whistleblowing policy) provides staff with a secure means of communicating concerns and protected disclosures, with the option to do so anonymously. There have been no instances of modern slavery reported in the financial year ended 31 July 2022.
We aim to adopt the highest possible standards and take all reasonable steps to safeguard the children and adults at risk (“Vulnerable Groups”) we engage with. We recognise our duty to promote the welfare and well-being of Vulnerable Groups, to protect them from harm and to respond to abuse, exploitation and safeguarding concerns when they arise. We are committed to providing a safe environment where Vulnerable Groups feel safe, valued and respected.
We have an established safeguarding team including a designated Board level safeguarding lead. We have procedures and guidance in place underpinned by education to ensure that staff recognise what constitutes poor practice and abuse, and their responsibilities to respond appropriately. Our Safeguarding Policy, which is refreshed annually, is available via the following link: https://www.premierleague.com/safeguarding.
Supplier Due Diligence
We expect all our consultants, contractors, suppliers and other business partners (together “Suppliers”) to adopt the same high standards that we adhere to. As part of our contracting process, where appropriate, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our Suppliers will hold their own suppliers to the same high standards.
Our standard terms and conditions for Suppliers include an express obligation that they comply with the Modern Slavery Act 2015 in both letter and spirit as well as an associated immediate termination right should a breach of that express obligation occur.
As part of the process of identifying and assessing any actual or potential involvement in modern slavery or human trafficking in our supply chain we require those employees responsible for procuring services to consider the risk of potential issues relating to modern slavery and human trafficking through our supplier onboarding process. We encourage openness and will support anyone who raises genuine concerns about any issue or suspicion of modern slavery or human trafficking in any parts of our business or supply chains.
We use due diligence software to risk assess Suppliers prior to contracting with them for their services. This software, provided by a market leading third party, rigorously screens suppliers before delivering a report exposing any adverse media or other relevant information associated with that supplier. This allows us to make an informed assessment, obtain further information and introduce additional safeguards where necessary. Once screened, suppliers are subject to continuous monitoring, with any changes to risk status notified to us.
Looking to the Future
Our key aims for next year are:
1. to refresh the bespoke training on modern slavery issues available to our employees.
2. as we look to establish the presence of our business in new territories, to develop our Supplier due diligence process by ensuring that tailored questions are issued to those suppliers who operate in higher-risk areas to verify what their standards, policies and programmes are relating to human rights and modern slavery issues.
Assessment of Effectiveness
This statement constitutes our anti-slavery and human trafficking statement for the financial year ending 31 July 2022. We will continue to assess the effectiveness of the measures we take and we will regularly review and refine our policies and procedures, and the mandatory training provided to staff, in relation to modern slavery and human trafficking and will include updates on any actions we take in future statements.
This statement has been approved by The Football Association Premier League’s Board of Directors on 5 December 2022. A revised statement, detailing the steps taken and improvements made, will be published on the Premier League’s website each year at www.premierleague.com.
Click the link below to download a PDF version of the Anti-Slavery and Human Trafficking Statement, signed by Premier League Interim Chair Gary Peter McCormick OBE.
- Anti-Slavery and Human Trafficking Statement
- Size: 1.4MB
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