PGA European Tour and its subsidiaries, which include (among others) PGA European Tour Productions Limited, (together the “PGA European Tour group”) are committed to upholding integrity and sportsmanship as we showcase our diverse global talent. We recognise that modern slavery is a growing problem worldwide and we are committed to taking all reasonable actions to ensure that there are no acts of modern slavery and human trafficking within our supply chain or in any part of our business. We impose those same high standards on our consultants, contractors, suppliers and other business partners (together the “Suppliers”). In accordance with section 54 of the Modern Slavery Act 2015, we set out below the steps that have been taken by the PGA European Tour group during the financial year ending 31 December 2021 to seek to prevent slavery and human trafficking in our business and supply chain.
Our Business and Supply Chain
PGA European Tour group operates a broad range of business initiatives essential to its primary mission of promoting, managing and administering professional golf tournaments. It is a unique business which generates profits for the benefit of its members – the tournament players – who receive their returns by way of competing and winning prize money. The PGA European Tour group comprises a number of subsidiaries and joint venture entities engaged in the promotion, management and administration of the business, all of which are managed and controlled as a single entity to achieve its objectives.
PGA European Tour group currently operates the two leading men’s professional golf tours in Europe, namely the European Tour and the Challenge Tour (each a “Tour”) as well as assisting in managing the staging of the Ryder Cup in Europe once in every four-year cycle. Each Tour includes tournaments sanctioned by PGA European Tour alone or co-sanctioned alongside other international tours, with such tournaments being staged and promoted by the PGA European Tour group, another international tour or by third party promoters. The 2021 tournament schedule spanned Europe, Africa and the Middle East with the PGA European Tour group itself responsible for staging 16 events where we employed local temporary staff and volunteers through bona fide recruitment agencies.
The business is run by a professional staff of around 275 employees within its registered office in Virginia Water, England, and its representative offices and international branches. Our supply chains can be cross-border and include third party suppliers of products and services required for our commercial, broadcasting and tournament operations. These include, amongst others, suppliers of the following products/services:
• Audio-visual equipment and services
• Professional services
• TV Production
• Catering products and services
• Property management services
• Consultancy services
• Recruitment services
• Education and training services
• Security services and police
• Financial services
• Ticketing and accreditation services
• Health and Safety consultancy
• Travel and accommodation services
• IT equipment / software / hardware
• Marketing / advertising / design services
• Medical treatment / supplies
To find out more about our business please view here: www.europeantour.com/en/europeantour/corporate-news/
Our Policies and Procedures relevant to our Commitment and Preventing Modern Slavery
We strive to ensure we have robust commercial agreements, employment contracts, employment and recruitment-related policies and procedures in place which are updated regularly. No form of slavery will be tolerated within our business.
The PGA European Tour group’s Procurement Policy sets out our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. Our Whistleblowing Policy details how to report any suspected breach. We have a Modern Slavery Guidance Note to ensure any report of modern slavery or human trafficking is dealt with effectively and efficiently by a working group set up for this purpose.
The PGA European Tour group sets out its approach to ethical trading within its Procurement Policy, a copy of which may be requested from the Company Secretary. Our Procurement Policy outlines our activity in relation to social, environmental and ethical impacts of our supply chain and governs how we manage relationships with Suppliers and what we expect of them in relation to modern slavery and otherwise.
Our standard terms of business require our Suppliers to comply with all applicable laws and include specific obligations upon our Suppliers to:
• comply with all laws relating to modern slavery; and
• implement due diligence procedures in relation to their own suppliers to ensure there is no slavery or human trafficking in their supply chains.
In addition to these terms, which we endeavour to incorporate in all relevant contracts, we continue to review our purchasing procedures as set out in the section below.
Risk Assessment and Due Diligence of Supply Chains
As part of the PGA European Tour group’s efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we understand that we need to adopt robust risk assessment and due diligence procedures and we continue to work towards this goal. We recognise that there may be markets in which our Suppliers operate which are more vulnerable to adverse practices than others and we take seriously the need for greater scrutiny regarding such Suppliers.
In relation to existing Suppliers, we are working towards implementing increased risk assessment processes, which will take into account the physical location of the Supplier and the nature of the goods / services supplied. Where any existing Supplier is considered to fall into the category of high or medium risk as a result of such assessment, that Supplier will be required to make a positive written affirmation that (i) they do not; and (ii) their direct supply chain does not, endorse, enable or facilitate human trafficking or slavery within their business, and we continue to work to build this into our various processes. All of our Suppliers are informed of the fact that we as a business operate a zero-tolerance approach to human trafficking and/or slavery. Failure by any existing Suppliers to provide the positive affirmations described above will lead to an investigation and may result in that Supplier’s contract being terminated, however we have had no cause to take any such action to date. Failure by a potential new Supplier to provide requested positive affirmations is likely to disqualify them from becoming a Supplier.
This year we reviewed and revised the terms of our largest procurement contract measured on our spend. In total 53 procurement contracts have been reviewed this year and a revised Modern Slavery clause incorporated. In addition, our standard Purchase Orders have been amended to include a Modern Slavery clause.
Two more employees have been added to the Procurement team to assist with the workload of the team.
Additional due diligence may also be undertaken by way of a physical audit / inspection of the Supplier if deemed necessary to satisfy the PGA European Tour group that the Supplier is operating to the required standard.
Assessment of Effectiveness
In order to assess the effectiveness of the measures we take, we regularly review our policies and procedures in relation to modern slavery and human trafficking and will include updates on any actions we take in future modern slavery statements.
In 2021 we have continued regular monitoring of our supply chain including review meetings focussed on policing compliance.
Training and awareness raising
Last year we included modern slavery training in our suite of compliance training sessions across all employees. This course will be rolled out on an annual basis and the course is provided to all new starters.
We continue to undertake strategic assessment of new suppliers in accordance with our Procurement Policy and monitor our supply chain pursuant to our contract approval mechanism.
Corporate, Social Responsibility and Sustainability review
A working group is responsible for reviewing our impacts on the environment and society to ensure we continue to seek excellence in every aspect of our business; meeting our business requirements while minimising the social, environmental and ethical impacts of those requirements.
We intend to take the following further steps to tackle this issue during the coming financial year:
• continued awareness raising sessions for our management and colleagues expanding on the annual training already implemented;
• continued regular monitoring of our supply chain including review meetings focussed on policing compliance; and
• continued focus on due diligence in relation to our business and supply chain and the use of Docusign.
Board Approval and Director’s Signoff
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes the PGA European Tour group’s slavery and human trafficking statement for the financial year ending 31 December 2021.
This statement was approved by the Board on 27th June 2022 and is signed on the Board’s behalf and on behalf of PGA European Tour and its group companies.
Name: David Williams
Date: 27th June 2022