Modern Slavery Act Statement

The purpose of this statement is to set out how we are managing the risk of modern slavery and the steps taken by us to prevent modern slavery taking place in our business and supply chains.

ABOUT US – STRUCTURE

CFG is a holding company established to oversee a multinational network of linked football clubs and other football operations. CFG’s operations are organised into football clubs and service companies which support the main football business and cover business operations including: sponsorships, partnerships, merchandising, ticketing, hospitality and marketing. The Club is a professional football club and participated in both domestic and European club competitions during the 22/23 season.

CFG’s ultimate majority shareholder is HH Sheikh Mansour. CFG has its head office in the UK at City Football HQ, 400 Ashton New Road, Manchester, England, M11 4TQ and, on a consolidated basis, has an annual turnover of more than £36m. CFG and the Club’s financial year end is 30 June.

OUR COMMITMENT AND APPROACH

Modern slavery and human trafficking remain a blight on our global society and includes: slavery, servitude and forced or compulsory labour, all of which have in common the deprivation of a person’s liberty for exploitation or commercial gain.

We are committed to conducting our business in an ethical and lawful manner and this statement sets out our zero-tolerance approach to modern slavery and human trafficking, in all its forms. Everyone in our business has a responsibility to be alert to the risk of modern slavery and human trafficking, however small, both within our business and in our wider supply chain and partnerships. Our workforce are required to report any concerns about modern slavery and human trafficking and management are required to act upon them.

As part of our culture of corporate governance best practice, we 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 particularly the offences under the MSA 2015.

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 chains.

OUR SUPPLY CHAIN & DUE DILIGENCE PROCESSES

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.

We ensure robust procedures are in place for onboarding new suppliers through our Procurement Policy. 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, including our zero-tolerance approach to slavery and human trafficking. With regards to national or international supply chains, our preferred point of contact is with a UK company or branch and we require these entities to have suitable anti-slavery policies and procedures in place.

Our standard contractual terms of business require our counterparties to comply with applicable laws in relation to anti-slavery and human trafficking, to incorporate equivalent terms in their own contractual arrangements, and an obligation to notify us should they become aware of any slavery or human trafficking in their own supply chains.

As set out above, we have a zero-tolerance approach to modern slavery and we expect all those in our supply chain, including contractors, to comply with our values. Our senior management are responsible for compliance with our 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 team and reporting via the Audit Committee.

LIVING WAGE & RECRUITMENT PROCESS

We believe our staff deserve a wage which meets their everyday needs and is why we are an accredited member of the Living Wage Foundation, whereby we voluntarily agree to pay each member of staff over the age of 18 a fair wage that is aligned with the cost of living. Further, we require any supplier who provides staff to work at our sites to provide the same^[1].

We acknowledge the risk of modern slavery and human trafficking arising through our recruitment and therefore operate a robust recruitment process, which includes mandatory DBS checks, references and pre-recruitment right to work checks. The pre-recruitment right to work check is a particularly important risk management tool to enable us to ensure that each individual employed by us has the right to work in the UK and has not been illegally trafficked to the UK. We have recently undertaken a thorough review of our pre-employment checking processes and have refined them to layer additional safeguards in our ways of working.

SAFEGUARDING

CFG and the Club recognise the importance of promoting and protecting the rights, safety, dignity and well-being of all children, young people and adults at risk of harm, who are in contact with any of our activities. We have a dedicated safeguarding team that has established best practice safeguarding policies and procedures pursuant to applicable statutory and regulatory guidance. Our safe recruitment processes contribute to the organisational mechanisms that help to prevent issues of human trafficking and modern slavery.

All individuals connected with CFG and the Club are encouraged to report any safeguarding-related concerns they experience, including those which may fall within the definitions of modern slavery and human trafficking. We will respond to any such concerns with sensitivity and in the strictest confidence and where appropriate make referrals to the relevant statutory authorities.

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING

We use 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 recruitment policies 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. We will continue to review and update our policies and procedures in relation to modern slavery and human trafficking.

Approved by the CFG Board of Directors on 2 March 2024. 

Signed for and on behalf of the CFG Board of Directors.

Simon Cliff
Group General Counsel and Company Secretary