Slavery and human trafficking statement pursuant to section 54(1) of the Modern Slavery Act 2015 (“MSA2015”)
Slavery and human trafficking remains a hidden blight on our global society and includes: slavery, servitude and forced or compulsory labour; and, human trafficking. Everyone in our business has a responsibility to be alert to the risks, however small, both in our business and in the wider supply chain and partnerships. Staff are expected to report concerns and management are expected to act upon them.
As part of our culture of corporate governance best practice, City Football Group Limited and its subsidiaries (“CFG”, “we”, “us”, “our”) operate to a set of core values reflecting our relationships with our principal stakeholders and partners. We adopt a behavioural value for all business relationships, reflecting our attitude to the exploitation of individuals, in any form and more particularly the offences under the MSA2015. We are committed to opposing modern slavery in all forms and preventing it by whatever means possible. We demand the same attitude of all who work for and with us.
CFG is a holding company established to oversee the creation and administration of a network of linked clubs and other football operations. CFG is run as a holding company with the majority shareholder being Abu Dhabi United Group Investment and Development Limited, and the minority shareholders being CMC Inc and Silver Lake. CFG has its head office in the UK and has an annual turnover of more than £36m. CFG’s financial year end is 30 June.
Our operations are organised into football clubs and service companies which support the main football business.
Our supply chain includes securing sponsorship and marketing partnerships, the procurement of IT media and other services relating to the football and sports industry and the sourcing of raw materials.
CFG, through its Procurement Policy, demonstrates the highest levels of environmental, economic and social value. To achieve sustainable procurement, we manage conflicting issues internally and with key partners and stakeholders.
SLAVERY AND HUMAN TRAFFICKING PRACTICES
CFG is committed to ensuring there is no modern slavery or human trafficking in our supply chain or in any part of our business. Our Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk, we prefer to build long-standing relationships with local suppliers and clearly outline our expectations for business behaviour. With regards to national or international supply chains, our preferred point of contact is with a UK company or branch and we expect these entities to have suitable anti-slavery and human trafficking policies and procedures. We expect each entity in the supply chain to adopt due diligence on the next link in the chain. In addition, we have processes to encourage the reporting of concerns and which protect whistle-blowers.
To improve our understanding of the risks of modern slavery and human trafficking, we are implementing a Modern Slavery Act e-learning module for new joiners as well as for existing staff.
PARTNER ADHERENCE TO OUR VALUES
Our stance remains zero tolerance to slavery and human trafficking and we expect all those in the supply chain and contractors to comply with our values. The CFG senior management are responsible for compliance in their respective departments and for their supplier relationships. Our Directors remain briefed on the subject via members of the CFG senior management and the Audit Committee.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
CFG use the following key performance indicators to measure how effective we have been to ensure that slavery and human trafficking is not taking place in our business or supply chain: the internal and external Audit process; the monitoring of Human Resource and payroll systems, including the use of preferred employment agencies; and, direct communication with our suppliers ensuring their understanding of, and compliance with, our expectations.
Our attitude to modern slavery remains: zero tolerance.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes CFG's slavery and human trafficking statement.
Approved by the CFG Board of Directors on 21 December 2019.
General Counsel and Company Secretary