Modern Slavery Act Statement
Everton is committed to having a zero tolerance approach to any modern slavery practices within the Club and our supply chains. In this statement we explain our current policies and the work we have undertaken to ensure compliance with the Modern Slavery Act 2015 (MSA), along with our future proposals to strengthen our compliance.
Our MSA Aims
Given Everton’s position at the heart of the community, its family ethos and being a values based organisation, we have developed a 5 year “Club Modern Slavery Act Strategy”. Everton’s aim is to go beyond mere legal compliance by taking meaningful, sustainable and ethical best practice steps to help ensure there is no modern slavery within any of our supply chains.
Our Current Policies and Procedures
Everton respects the right to work freely and with equal opportunity. We have clear policies which set out how we expect our employees to behave and conduct themselves. These policies also apply to those who work at our place of business on our behalf, including contractors, suppliers and those on temporary/ad hoc employment.
All of the Club’s current written policies and procedures for employees which touch upon modern slavery risks and behaviours are periodically updated and presented to staff. All new starters are provided with training in these areas and current staff are provided with continuous training where necessary or where the law changes.
The policies which govern how we treat fellow employees and conduct our operations include:
- Anti-Bribery Policy
- Anti-Harassment and Bullying Policy
- Equal Opportunities Policy
- Grievance Policy
- Pay Policy
These policies ensure the protection of human rights and compliance with employment legislation, with a view to the elimination of discrimination in the work place. These encourage an atmosphere of openness and provide an effective remedy for anyone who may feel they are suffering from behaviour indicative of modern slavery.
Everton plans to incorporate more specific MSA training into these policies and the induction of new employees. As part of our MSA strategy, we intend to review and, where required, strengthen sections of our policies in light of the recent introduction of the MSA.
Our Current Suppliers
Our commercial and supply agreements with our suppliers are, wherever possible, made subject to all applicable legislation, including the MSA. These agreements regarding the supply of services and products to Everton are conditional upon our partners, sponsors and suppliers acting in accordance with the relevant laws, rules and regulations which affect their operation of that agreement including any practices that may be indicative of modern slavery behaviours.
As part of our MSA strategy, we intend to include specific MSA policies in new supplier agreements which encompass MSA areas of supply chains such as procurement, purchasing, manufacturing and human resources.
Our MSA Actions in 2015/2016
Our aim is to look further into our operations and identify any areas at risk of modern slavery and human trafficking. To achieve this goal, we have worked with business ethics specialists to assist Everton with the review of our current MSA stance and develop a strategy for the Club in this area. Beginning this year we have:
- Reviewed ways to assess MSA compliance of our top suppliers
- Produced modern slavery risk assessment questionnaires for completion by our top suppliers
- Developed a 5 year Club MSA Strategy
Our initial focus has been on risk assessment to ensure the correct targeting of resources and actions for effective elimination of the risks of modern slavery within our supply chains.
These actions are the foundation for the steps that will be taken in the first year of our MSA Strategy to establish the main priority areas for Everton’s modern slavery efforts.
Club MSA Strategy
We have created a 5 year action plan for Everton’s MSA Strategy. This involves a combination of risk assessment, policy review, due diligence, performance assessment and an overarching strategy implementation. These strands are implemented in our 5 year action plan in the table below:
>View Strategy Document
We will monitor the results of the MSA Strategy to update our policies as required and to prevent any exploitation of people involved in our supply chains and in the Club. We intend to improve our MSA compliance year on year and make the right decisions to become a best practice organisation for MSA compliance in the Premier League.
This statement covers the financial year ending 31 May 2016 and has been approved by the Board of Directors of the Everton Football Club Company Limited.
Director and CEO, Everton Football Club