THE LIVERPOOL FOOTBALL CLUB AND ATHLETIC GROUNDS LIMITED ANTI-SLAVERY AND HUMAN TRAFFICKING STATEMENT
The Liverpool Football Club and Athletic Grounds Limited ("LFC") recognises that the respect for human rights is an integral part of its social responsibility as a responsible Premier League football club.
LFC has fostered and continues to foster an organisational culture that respects dignity and human rights. We believe that conducting business with high ethical standards is fundamental to this culture.
LFC is also subject to the requirements of the Modern Slavery Act 2015 (“Act”) and we are committed to ensuring that no modern slavery takes place in our organisation. We also want to prevent workers from being subjected to modern slavery in our supply chains and within the businesses of our partners.
This statement sets out the actions that LFC has taken to understand all potential modern slavery risks in relation to its organisation and to put in place steps aimed at ensuring that there is no slavery or human trafficking in its business and supply chains. This statement relates to actions and activities of the Club during the financial year up to and including 31 May 2018.
Approach and Policies
We continue to review and ensure adherence to our Anti-Slavery and Human Trafficking policy, which reflects our commitment to acting ethically and with integrity in all our business relationships, and sets out the steps that we are continuing to take to combat modern slavery. We also ensure that our staff are reminded of the importance of this policy and encourage them to raise concerns about any suspicion of modern slavery in any part of our business or supply chains.
Additionally, our Supplier Code of Conduct requires all third parties working with LFC to comply with all labour laws in the jurisdictions where they operate, and to take appropriate steps to ensure that there is no slavery or human trafficking in their own supply chains.
LFC continues to undertake increased levels of due diligence on all proposed third parties prior to entering into agreement with them to ensure that those third parties connected to LFC conduct themselves in a manner conducive to the Act and to the highest ethical standards expected by LFC.
Supplier Mapping and Risk Assessment
We are the majority of the way through the process of mapping out our first tier supply chain in order to identify particular risks which require attention. This has fed into the development of an on-going program which ensures our systems:
- Identify and assess potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
- Protect whistle blowers.
Various teams within LFC have been working together to ensure this process is thorough, and all-encompassing across the business and effective and as this is being completed, LFC continues to assess and mitigate any of those risks flagged.
We have now conducted numerous ethical audits, and will continue to conduct such audits, of our suppliers to ensure compliance with our Supplier Code of Conduct and we continue to work with our suppliers to assist them in identifying any areas of risk in their own supply chains and to mitigate the risk of modern slavery occurring.
Contracts and Procurement
Our contractual and procurement approach has always been to try and include relevant and binding provisions in our key external supply contracts to ensure our suppliers and our partners trade ethically and take appropriate steps to ensure there is no slavery or trafficking in their business. These protections will continue to be included in all key external supply contracts going forwards. We have also updated the language in our supply contracts to ensure that third parties warrant their compliance to the Act in all dealings with or on behalf of LFC and to increase the robustness of LFC’s audit rights in respect of our supply contracts so if we suspect or have reason to suspect non-compliance, we can act swiftly and accordingly.
Training and Awareness
In order to ensure that our key staff understand and are aware of the risks of modern slavery and human trafficking and can assist us in preventing this, both in our business and in our supply chain and the businesses of our partners, we continue to provide training to representatives from our board of directors, management team, HR team and procurement team.
LFC will continue to take specialist legal advice to ensure it is informed of any updates or changes to its obligations under the Act.
LFC remains committed to upholding human rights and safety in our supply chain and we will be reviewing our progress and effectiveness in combatting slavery and human trafficking on an annual basis.
This statement is made pursuant to section 54(1) of the Act and constitutes our slavery and human trafficking statement for the financial year ending 31 May 2018.
Andy Hughes, COO, Director
On behalf of The Liverpool Football Club and Athletic Grounds Limited
Date: 30th November 2018