Slavery and human trafficking statement made by City Football Group Limited and its subsidiaries (together referred to as “CFG”, “we”, “us”, “our”) pursuant to section 54(1) of the Modern Slavery Act 2015 (“MSA2015”)
ABOUT US - STRUCTURE
CFG is a holding company established to oversee the creation and administration of a network of linked football clubs and other football operations. Our operations are organised into football clubs and service companies which support the main football business. CFG’s majority shareholder is Abu Dhabi United Group Investment and Development Limited, and the minority shareholders are CMC Inc and Silver Lake. CFG has its head office in the UK at City Football HQ, 400 Ashton New Road, Manchester, England, M11 4TQ and has an annual turnover of more than £36m. CFG’s financial year end is 30 June.
This statement sets out CFG’s approach to modern slavery. Modern slavery remains a hidden blight on our global society and includes: slavery, servitude and forced or compulsory labour; and, human trafficking, all of which have in common the deprivation of a person’s liberty for exploitation or commercial gain. Everyone in our business has a responsibility to be alert to these risks, however small, both in our business and in our wider supply chain and partnerships. Staff are expected to report any concerns about modern slavery and management are expected to act upon them.
CFG has a zero tolerance approach to modern slavery of any kind. As part of our culture of corporate governance best practice, CFG and its subsidiaries, including Manchester City Football Club Limited, operate to a set of core values reflecting our relationships with our principal stakeholders, supply chain and partners. We adopt behavioural values for all business relationships, reflecting our position against the exploitation of individuals, in any form and in particular 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.
Our supply chain includes securing sponsorship and marketing partnerships, the manufacture and supply of our licensed products and merchandise, kit and equipment, the procurement and sourcing of a range of services such as IT, media, marketing, security, consultancy, professional services, catering, hospitality and other services relating to the football and sports industry and the sourcing of various products used within our business.
CFG is committed to ensuring there is no modern slavery in our supply chain or in any part of our business. Our Anti-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 business or in our supply chain.
CFG, through its Procurement Policy, demonstrates the highest levels of environmental, economic and social values. To achieve sustainable procurement throughout our supply chain, we manage conflicting issues internally and with key partners and stakeholders.
DUE DILIGENCE PROCESSES
As part of our approach to identify and mitigate any risk of modern slavery in our supply chain, 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 policies and procedures in place. We expect each entity in our 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.
PARTNER ADHERENCE TO OUR VALUES
As set out above, CFG has a zero tolerance approach to modern slavery and we expect all those in our supply chain, including contractors to comply with our values. CFG’s senior management are responsible for compliance with the company’s approach to modern slavery in their respective departments and in their supplier relationships. Our Directors are informed of the subject via members of CFG’s senior management and the Audit Committee.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
CFG uses 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 in our 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 and zero tolerance approach to modern slavery, including human trafficking.
Approved by the CFG Board of Directors on 2 March 2021.
General Counsel and Company Secretary