This Statement explains the steps taken by Arsenal Holdings Limited and its subsidiary companies (the "Arsenal Group") to prevent modern slavery in its business and supply chains.
The term "modern slavery" used in this Statement includes slavery, servitude, any type of forced or compulsory labour and human trafficking. References to "we ll, "us" or "our" in this statement are to the Arsenal Group.
We published our first Modern Slavery Statement in October 2016. This latest Statement is in relation to the financial year ended 30 May 2019.
Arsenal Football Club is a professional football club which plays its home matches at Emirates Stadium and participates in domestic as well as European club competitions. We have a number of other business operations, including; football operations, commercial partnerships, media distribution, ticketing, retail, property development and community projects.
The majority of our operations are conducted in the UK through The Arsenal Football Club PLC, which is a subsidiary of Arsenal Holdings Limited. In addition to our activities in the UK, we have some limited overseas activities in Jersey, Singapore and the United States of America. For further information about our group, its organisational structure and operations, see: www.arsenal.com
Our Approach to Modern Slavery
The Arsenal Group has had a long-standing commitment towards ethical, social and environmental responsibility within its business. We comply with all applicable labour laws relating to working terms and conditions, including pay, and we place great emphasis on equality and diversity.
The Arsenal Group is committed to seeking to ensure that modern slavery does not exist in its business or supply chain. As part of that commitment, we implemented our Modern Slavery Policy, overseen by an MSA Compliance Officer, to operate alongside and supplement our existing corporate and people policies that help us ensure that our business operates in an ethical and responsible way. These include our Health & Safety Policy, Equal Opportunities Policy, Anti-Corruption Policy, Whistleblowing Policy, Conflicts of Interest Policy, Safeguarding Children and Young People Policy and Procedures and Safeguarding Adults at Risk Policy and Procedures.
We also reviewed our operations and our supply chain to assess the risk of modern slavery taking place and undertook a risk assessment of these by reference to a number of factors, including: the nature of our activities, their location, the sources from which we are supplied goods or personnel, the risk profile of relevant locations, and any other relevant cultural, economic or operational factors.
On the basis of this assessment, we introduced further steps to seek to ensure that modern slavery does not take place in our operations or our supply chain, including the implementation of our Modern Slavery Policy.
Our approach and the steps taken in relation to modern slavery have the full support of our Executive Team which oversees all strategic decisions in this area.
Our Supply Chain
We seek to partner with suppliers that share our values, and we expect our supply chain to operate fair and equitable practices, whereby modern slavery is not tolerated.
As indicated above, the Arsenal Group developed a risk-based approach to assess the likelihood of the existence of modern slavery within our supply chain. This risk assessment is an ongoing exercise for our existing supply chain, as well as for potential new suppliers.
Over time we continue to strengthen our understanding of supply chain risk across our business. Within our retail operations, for example, we reviewed all direct manufacturing suppliers to assess modern slavery risks in these supply chains. This exercise resulted in new contractual requirements for those relevant suppliers to provide us with detailed audit information for assessing their compliance with relevant laws and the Ethical Trading Initiative's code of practice.
In due course, and to supplement our due diligence work to date, we are looking to engage select key suppliers which display an enhanced risk profile and work together to identify and implement effective measures for mitigating modern slavery risks in their supply chains.
We also continually review the contractual terms and conditions that we put in place with our suppliers to ensure that, wherever appropriate, these include provisions which effectively address the risks of modern slavery.
Before being formally appointed, any new suppliers which we consider to represent a risk of modern slavery are required to satisfy us that they operate in a manner in which modern slavery is not tolerated, and relevant risks are addressed. Our assurances in this regard may include appropriate contractual provisions (see above), backed up by audits and on-site inspections by a credible and independent third party, where appropriate, as well as an assessment of their policies, procedures, processes and values.
Once this exercise is completed, our MSA Compliance Officer, Safeguarding Team and Executive Team will consider whether we are satisfied that any modern slavery risks are being appropriately addressed and we reserve the right to refuse to appoint any supplier whose operations and/or supply chain fail to meet our requirements.
If we or anyone working for us becomes aware of any instance of modern slavery occurring within our operations or our supply chain, our Modern Slavery Policy provides for the reporting of these matters to an appropriate manager and/or the MSA Compliance Officer. Where a supplier is implicated, we will engage with the relevant supplier(s) and implement an appropriate and timely response. This may include the immediate termination of the supply agreement. In all instances, however, we would seek to prioritise the safest outcome for the victims of the modern slavery activity. There have been no instances of modern slavery reported in the financial year ended 30 May 2019.
The Arsenal Group has also continued to develop a training programme for members of staff working in relevant functions across our operations which we have identified as having a higher risk of modern slavery. In the future, we also aim to roll out an online training course for all staff.
The aim of this training is to increase awareness of modern slavery issues and to help members of staff understand them and be alert to relevant indicators, their particular relevance to the Arsenal Group, and those members of staff's role in managing them in accordance with our values and our Modern Slavery Policy. The programme will continue to be developed and adapted to the Arsenal Group's areas of focus in respect of potential risk.
Within our supply chains, the Arsenal Group aims to assist and work alongside all suppliers as they implement enhancements to the modern slavery policies and risk management processes in their own businesses.
The MSA Compliance Officer is responsible for ensuring continued monitoring of the effectiveness of our Modern Slavery Policy and for ensuring appropriate steps are taken should any issues arise.
Approved by the Board of Directors of Arsenal Holdings Limited on 29 October 2019.
Director, Arsenal Holdings Limited
Copyright 2019 The Arsenal Football Club plc. Permission to use quotations from this article is granted subject to appropriate credit being given to www.arsenal.com as the source.