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 second 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.
Since our statement published last year, we have built upon our existing measures with the implementation of an enhanced supplier due diligence system, as well as the introduction of a hotline and web-based reporting service for whistleblowing. An online training programme, to educate and inform staff of the risks of modern slavery and human trafficking, has also been implemented.
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 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
- Consultancy services
- Educational services
- Financial services
- Food and beverages
- Football operations
- Insurance services
- IT equipment/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
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. 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 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.
Training on the Policy and on the risk that the business faces from modern slavery in its supply chains forms part of our induction process. To maintain awareness amongst existing staff, we have developed an interactive, online learning module. The module, which is compulsory for all staff to complete, was made available January 2018 and provides context as to how the crimes of modern slavery and human trafficking may be committed. It also highlights potential warning signs for employees to be aware of.
In order to support and bolster the effectiveness of the Policy and the accompanying training, we have engaged a third party supplier to provide 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) will give staff an additional, secure means of communicating concerns and protected disclosures, with the option to do so anonymously.
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 a designated safeguarding lead, 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.
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 the 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 part of the process of identifying and assessing any actual or potential involvement in modern slavery in our supply chain we require those employees responsible for procuring services to consider the risk of potential issues relating to modern slavery through our supplier onboarding process. We encourage openness and will support anyone who raises genuine concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains.
Since our first statement, we have introduced an enhanced due diligence system to risk assess Suppliers prior to contracting with them for their services. This system, provided by a third party, rigorously screens suppliers before delivering a report exposing any misconduct associated with that supplier, allowing us to make an informed assessment. Further information can be requested via the system should any risks be highlighted. Once screened, suppliers will be subject to continuous monitoring, with any changes to risk status notified to us.
This statement constitutes our anti-slavery and human trafficking statement for the financial year ending 30 June 2017. We will continue to assess the effectiveness of the measures we take and we will regularly review and refine our policies and procedures 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. 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 Executive Chairman Richard Scudamore.
- Anti-Slavery and Human Trafficking Statement
- Size: 1MB
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