Everton Football Club and the Everton Family are 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 developed a five-year “Club Modern Slavery Act Strategy” following the introduction of this legislation. 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 ongoing 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
- Confidential Reporting 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. They encourage an atmosphere of openness and provide an effective remedy for anyone who may feel they are suffering from behaviour indicative of modern slavery.
We have delivered training on the MSA to all managers within the organisation and have now added the MSA as a standard topic for the Club’s induction which is delivered to all new starters. This has rendered a stand-alone MSA policy unnecessary.
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 now include specific MSA provisions in new supplier agreements which encompass MSA areas of supply chains such as procurement, purchasing, manufacturing and human resources. We have also developed a questionnaire regarding MSA compliance which must be completed by key suppliers as part of the due diligence process.
Our MSA Actions in 2019/2020
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. Over the past four years, we have:
- Reviewed ways to assess MSA compliance of our top suppliers
- Introduced due diligence checks for all new suppliers and commercial partners
- Produced modern slavery risk assessment questionnaires for completion by our top suppliers
- Developed a 5-year Club MSA Strategy
- Delivered training to managers
- Become an accredited Living Wage Foundation (LWF) employer and principal partner of the LWF helping to influence policy in this area
- Added MSA training to the Club’s induction
- Introduced a new ‘Confidential Reporting Policy’ to empower staff members to ‘blow the whistle’
- Participated in an external report into Football and Modern Slavery conducted by UNH Scotland
- Participated in All Party Parliamentary Group meetings on Modern Slavery at the House Of Lords
Our initial focus was 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. We have since turned our attention to implementing specific policies and training programmes to ensure ongoing compliance with the MSA. To date, we have experienced no instances of non-compliance.
We are committed to protecting children and young people who are at risk of being exploited by parents, carers, family members or bogus agents. Our Safeguarding team is qualified to identify such issues and provide support to those affected.
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:
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 2020 and has been approved by the Board of Directors of the Everton Football Club Company Limited.