MODERN SLAVERY STATEMENT
PGA European Tour and its subsidiaries which include (among others) and 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 and the proposed steps for the financial year to 31 December 2019 to ensure that we strive to prevent slavery and human trafficking in our business and supply chain.
OUR BUSINESS AND SUPPLY CHAIN
PGA European Tour 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 operates the three leading men’s professional golf tours in Europe, namely the European Tour, the Staysure 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 also includes sanctioned and co-sanctioned tournaments in Australasia, Asia, Africa and the Middle East. We are responsible for staging 13 tournaments around the world where we employ local and temporary staff and volunteers through bona fide recruitment agencies.
The business is run by a professional staff of around 250 employees within its registered office in Virginia Water, England, and its representative office in China and branches in France, Spain, Korea and Hong Kong as correct at the date of this statement. Our supply chains can be cross border and include third party suppliers of products / services required for our commercial, production & broadcasting and tournament operations. These include, amongst others, suppliers of the following products / services:
· Audio-visual equipment and services
· Catering products and services
· Consultancy services
· Education and training services
· Financial services
· IT equipment / software / hardware
· Marketing / advertising / design services
· Medical treatment / supplies
· Professional services
· Property management services
· Recruitment services
· Security services
· Ticketing and accreditation services
· Travel and accommodation services
The PGA European Tour Group’s annual turnover to 31 December 2018 was around £333,000,000. 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 TO PREVENTING MODERN SLAVERY
We have robust commercial agreements, employment contracts, employment-related policies and procedures and recruitment procedures in place which are updated regularly. No form of slavery will be tolerated within our business.
The Board of PGA European Tour adopted an Ethical Trading Policy which sets out the PGA European Tour Group’s 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 policy also includes a whistleblowing procedure which may be used to report any suspected breach.
The Board appointed its Company Secretary as Compliance Manager with the responsibility for day-to-day compliance with the Ethical Trading Policy. A copy of our Ethical Trading Policy may be requested from the Compliance Manager.
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 in their supply chains.
In addition to these changes to our standard terms of business, which we endeavour to incorporate in 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 will adopt robust risk assessment and due diligence procedures. 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 will work towards implementing an annual risk assessment exercise, 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 supplier process. 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 an existing Supplier 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 our Supplier.
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.
Following the PGA European Tour Group’s review of our actions to prevent slavery or human trafficking from occurring in our business and supply chain, we intend to take the following further steps to tackle this issue during the coming financial year: -
· training and awareness raising sessions for our management and colleagues;
· regular monitoring of our supply chain including review meetings focussed on policing compliance with this statement;
· plan for a review of our corporate, social responsibility and sustainability measures; and
· continued focus on contractual development and due diligence in relation to our business and supply chain.
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 2018.
This statement was approved by the Board on 24 June 2019 and is signed on the Board’s behalf and on behalf of PGA European Tour and its Group companies including PGA European Tour Productions as defined above.
Name: David Williams
24 June 2019