MODERN SLAVERY STATEMENT
PGA European Tour and its subsidiaries (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 preventing acts of modern slavery and human trafficking from occurring in 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 2018 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 administering professional tournament golf. 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 Senior Tour and the Challenge Tour. Each Tour also includes sanctioned and co-sanctioned tournaments in Australasia, Asia, Africa and the Middle East.
The business is run by a professional staff of over 200 employees within its registered office in Virginia Water, England, its representative office in China and its branches in France, Spain, Hong Kong and Korea.
Our supply chains include third party suppliers of products / services required for our commercial, 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
· Travel and accommodation services
The PGA European Tour Group’s annual turnover to 31 December 2017 was around £211,000,000. 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.
Despite our standard terms of business already requiring our suppliers to comply with all laws, we have updated these terms to include specific obligations upon our suppliers to:
· comply with all laws relating to modern slavery;
· comply with the terms of our Ethical Trading Policy;
· implement due diligence procedures in relation to their own suppliers to ensure there is no slavery in their supply chains;
· maintain complete records to trace the supply chain of all goods and services supplied to the PGA European Tour Group.
In addition to these changes to our standard terms of business, which we endeavour to incorporate in relevant contracts, we have also tightened up 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.
In relation to existing suppliers, an annual risk assessment exercise will be undertaken, taking 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, the 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 are currently building this into our new 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. Failure by a potential new supplier to provide requested positive affirmations is likely to disqualify them from becoming a Supplier to us.
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 will 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: -
· further training for our management and colleagues; and
· continued 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 2017.
Signed on the Board’s behalf and on behalf of PGA European Tour and its Group companies as defined above.
S E Gordon
1 January 2018