London Stadium 185 Limited - Modern Slavery and Human Trafficking Statement
This Statement sets out the steps that London Stadium 185 Limited (LS185) has taken to address the risks of slavery and human trafficking in our supply chains pursuant to section 54 of the Modern Slavery Act 2015 (the Act). Our aim is to inform our partners, suppliers, staff and the public about LS185’s policy with respect to identifying, preventing and mitigating the risks of modern slavery, human trafficking, forced and bonded labour and labour rights violations in our supply chains. It outlines the policies and processes we have in place, the areas we have identified as high risk, and the actions we have taken to mitigate such risks, and the plans we have in place to strengthen our commitment to the Act.
LS185 recognises the importance of compliance with the Act. This is LS185’s first annual Statement to be published setting out significant actions LS185 will undertake over the next 12 months to further strengthen its work in respect to modern slavery.
LS185’s structure, business and supply chains
LS185 is a subsidiary of E20 Stadium LLP (E20), a limited liability partnership which is ultimately controlled by the London Legacy Development Corporation (LLDC). LLDC is owned by the Mayor of London and is part of the Greater London Authority (GLA) Group. LS185’s purpose is to run and manage the London Stadium. In 2018, we spent over £22 million on goods and services with over 300 suppliers. Our supply chains are generally simple and involve predominantly UK companies. Nevertheless, we do source goods and services from further afield from time to time. We recognise the importance of taking appropriate steps to reduce the risk of modern slavery within our supply chains.
LS185’s policies in relation to slavery and human trafficking
- The GLA Group has a Responsible Procurement Policy which covers LLDC and its subsidiaries. It details best practice and compliance with the policy ensures that procurement activities meet all relevant legislative requirements including the Modern Slavery Act. The policy states that “businesses should consider human rights, labour standards, the environment and anti-corruption when making business decisions. We therefore always consider the measures that we can put in place to ensure that our services will be delivered in a manner that reflects these values. In this way, the GLA remains committed to extending its heritage of ethical sourcing and employment to its activities abroad.” LS185 will work to develop its own Responsible Procurement Implementation Plan, see the action plan below.
- As part of LS185’s standard Selection Questionnaire for OJEU procurements, prospective suppliers who are relevant commercial organisations as defined in the Act are asked to demonstrate compliance with the Act to LS185.
- LS185 is updating its Whistle Blowing Policy to include modern slavery and people trafficking as a matter regarded as malpractice.
Risk analysis on where there is a risk of slavery and human trafficking taking place
The principal categories that LS185 deems as carrying material risks of human rights abuses are stewarding, catering and facilities management services such as cleaning. Further risk and opportunity assessments to identify other contracts and areas of spend, where there may be a high risk, will be undertaken in the next 12 months.
LS185’s due diligence processes in relation to slavery and human trafficking in its business and supply chains
LS185 already undertakes audit assessment of payslips of contractors and sub-contractors which gives assurance through evidence that employees are paid, and at the London Living Wage level. We will examine options for embedding supply chain due diligence into its processes to address the risk of modern slavery, human trafficking, forced and bonded labour and other human rights risks in the supply chain. As a priority in 2020/21, attention will be paid to modern slavery risks in stewarding, catering and facilities management services, where lower pay is prevalent and where demand for unskilled labour in the supply chain may be met by third party agencies. Contractors will be encouraged to recruit directly wherever possible and to undertake regular audits of third-party agencies to check for the signs of human rights abuse.
- All new LS185 contracts will include clauses that oblige contractors to comply with the Act. As new standard contracts are developed for LS185, they will incorporate appropriate wording.
Effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate
LS185 undertakes an annual exercise with LLDC to write to LS185’s major suppliers in relation to payment of the London Living Wage and the non-exploitative use of Zero Hours / Worker contracts and business compliance with the Act and their related due diligence work with supply chains. The responses from the most recent exercise will be analysed and further information or monitoring visits will be requested where required.
Key staff in the Management Team will receive a training on Modern Slavery from the LLDC lead, along with guidance from the GLA Group’s Responsible Procurement team who have expertise in this field. Key staff will also join webinars on the subject and an E-learning module on Responsible Procurement is being rolled out to key LS185 staff.
Our key goals
LS185 reconfirms its commitment to better understanding its supply chains and working towards greater transparency and responsibility towards people working in them.
We will continue to work with our partners and suppliers to undertake supply chain due diligence and mitigate the risks to human rights in our supply chains. As LS185 acquires knowledge and develops capability across all higher-risk spend categories, the intention is to codify and communicate for wider use in the GLA Group those due diligence processes that are found to be the most successful.
In the next 12 months LS185 will pursue six key goals in relation to Modern Slavery:
These are owned by the LS185 Senior Executive Team
- Ensure all standard and bespoke LS185 contracts commit suppliers to actively co-operate with LS185 to identify and mitigate risks of modern slavery and human trafficking. Introduce a programme of training in promoting respect for human rights in supply chains for commercial staff in LS185 and an awareness raising briefing session for all staff. This will be undertaken by working with the LLDC’s Human Resources team.
- Commence a programme to encourage contractors in industries where low pay is prevalent to undertake regular audits of third-party employment agencies that they use to source workers, especially where workers are not then employed or paid directly by LS185’s contractors. This will be undertaken with support from the GLA Group’s Responsible Procurement team
- Complete a risk and opportunity assessment to identify other contracts and areas of spend, where there may be a high risk of poor working conditions, human rights abuses or negative impacts on security and crime.
- Work with LLDC’s Procurement teams to develop a Responsible Procurement Implementation Plan to ensure that we are meeting the requirements of the GLA Group’s Responsible Procurement Policy.
- Consider joining a group for sharing industry best practice.
Progress against these actions will be reported to the E20 Board at least twice a year.
This Statement has been produced for E20 Board approval and will be published on the Stadium’s website and reviewed at least once annually by E20 Board.
CEO, London Stadium