This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Greenwich Leisure Limited (GLL) has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. GLL has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
We manage and operate a wide range of facilities including – Leisure Centres, Gyms, Libraries, Children Centres and Adventure Playgrounds.
Our high risk areas
Our high risk areas based on our procurement activities are:
Maintenance - repairs and servicing / Cleaning Services / Catering & Concessions / Event Security / Stewards
Uniform & Clothing / Marketing materials / Branded Products / Equipment Purchase
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
1. Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
2. Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
3. Equality and Diversity Policy. This sets out GLL stance to ensuring it promotes equality and building a workforce which reflects the diversity of the local community, valuing the benefits brought by a wider range of individual background and experience.
4. Bullying and Harassment Policy. This ensures all employees have aright to be treated with consideration, dignity and respect and is committed to providing a working environment free from any form of harassment.
5. Pay Strategy. Ensuring GLL pay bands are above the National Minimum wage structure.
6. Purchasing Policy: Outlines a number of processes & guidance on Modern Slavery.
GLL operates maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. Where a supplier falls into one of our high risk category – (as identified but not limited to those areas identified) additional information will be requested from them to ensure compliance at regular intervals
We require that they confirm and evidence to us that:
1. They have taken steps to eradicate modern slavery within their business -
2. They hold their own suppliers to account over modern slavery
3. (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate)
4. For international suppliers – they are SEDEX or SMETA compliant and have certification or audits to prove this.
5. We may terminate the contract at any time should any instances of modern slavery come to light
Training & Guidance
We will regularly conduct training for our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.
Support and guidance is available for the wider GLL workforce from the central Procurement team.
Our performance indicators
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
Supply chains and contractors are asked relevant detail prior to engagement and regular checks are carried out to ensure any required certification is maintained.
Approval for this statement
The Company Directors and senior management shall take responsibility for implementing this policy statement and its objectives and will ensure adequate resources and investment to safeguard GLLs declaration that they are not knowingly involved in slavery within its supply chains.
This statement was reviewed and approved by the Board of Directors October 2021.