Modern Slavery Policy
Modern Slavery Statement
1st February 2023
Freemans Event Partners has zero tolerance for slavery and human trafficking in any form and is committed to combating all such practices. We are taking steps to improve our practices and to ensure so far as possible that our suppliers share those values and put them into effect.
2. Our Business
We operate an event partnering business throughout the UK and occasionally in Europe, offering food, beverage and technology services at events and locations. Details of our corporate structure appear on the “About Us” section of our web page.
3. Our Supply Chains
Our supply chains include: supplies of food, soft drinks, alcoholic drinks, technology products, utilities, construction and maintenance and a range of other products for sale in our service areas, including confectionary.
4. Our Policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business and this is reflected in our Corporate Social Responsibility Policy. This 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 are not taking place anywhere in our supply chains.
5. Due diligence process for slavery and human trafficking
As part of our initiative to identify and mitigate risk we have in place systems to:
• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Protect whistle blowers
6. Supply chain compliance/accountability
To ensure all those in our supply chain and contractors comply with our values we have in place a supply chain compliance programme. This consists of:
Supplier Code of Conduct
As part of our commitment, we have adopted a Freemans Supplier Code of Conduct to which we will hold our supply chain accountable. The Freemans Supplier Code of Conduct prohibits the use of forced, compulsory, bonded (including debt bondage) or indentured labour, involuntary prison labour, slavery, servitude or trafficking of persons and unlawful child labour.
Supplier Certification, Procurement and Contracts
We require all current suppliers to certify their compliance with the Freemans Supplier Code of Conduct, or in the case of large corporate suppliers and franchisors, their own equivalent standard code. As part of our standard procurement procedures, we consider each supplier’s conduct in regard to the Freemans Supplier Code of Conduct, when awarding and/or renewing business with the supplier. Contracts will be terminated as soon as possible in the event of a breach of the Code, or failure /refusal to certify willingness to comply. We will ensure that future contracts with our suppliers will require compliance with the new Freemans Supplier Code of Conduct (or equivalent standard Supplier Code).
We are committed to ethical and socially responsible conduct in the workplace. We seek to comply with all employment legislation, including conducting appropriate right to work checks prior to employment, to ensure all team members are fully entitled to work in the UK.
8. Training and Information
To ensure an understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide information and training, as appropriate, to all our team members.
The Freemans Supplier Code of Conduct has been circulated to all heads of department, and all relevant team members dealing with suppliers are required to familiarise themselves with it. A copy of our Corporate Social Responsibility Policy is available to all team members.
Freemans will review the Freemans Supplier Code of Conduct and Corporate Social Responsibility Policy each year, and any updates will be notified accordingly to all relevant team members.
9. Our effectiveness in combating slavery and human trafficking
We will use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
• Records to confirm all employees have the right to work in the UK
• Records that employees have received appropriate training
• Records to confirm suppliers have certified compliance with Supplier Code of Conduct
Modern Slavery is now a key agenda item for our Board of Directors and regular discussions take place to establish who in our supply chain may be at higher risk and any further practical steps we can take to mitigate those risks, and to ensure that all necessary processes are in place to facilitate appropriate action to combat slavery.
10. Future Progress
We intend to take the following further steps to ensure that there is no slavery or human trafficking in our supply chains:
• The Board will continue to discuss progress, review and update the supply chain mapping process and to co-ordinate further practical actions which can be taken to mitigate risks of slavery in the supply chain
• Those suppliers identified as potentially higher risk by the Board as a result of the supply chain mapping process will be asked to take part in a more detailed supplier audit process in order to test compliance with the Supplier Code of Conduct. In addition, a programme of audit visits to certain key suppliers will be planned.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Freemans Event Partners Group’s Slavery and Human Trafficking Statement for the financial year ending 2023/2024.
On Behalf of all Freemans Event Partners Group Companies
*Freemans Event Partners Group Companies include:
Freemans Event Partners (Holdings) Ltd Freemans Event Partners (Concessions) Ltd
Freemans Event Partners (Catering) Ltd Freemans Event Partners (Bars) Ltd
Freemans Event Partners (Logistics) Ltd Freemans Event Partners (Technologies) Ltd
Freemans Event Partners (Europe) Ltd Freemans Event Partners (Brand Partners) Ltd
Freemans Event Partners (Properties) Ltd
FREEMANS SUPPLIER CODE OF CONDUCT
The Freemans Event Partners Group (“Freemans“) has committed to a strict set of ethical principles, to guide us in our business dealings, and we expect all our suppliers to adhere to the same ethical principles. This Supplier Code of Conduct sets out the standards and principles which we expect our suppliers to comply with.
Laws, Ethical Standards and Human Rights
The supplier shall comply with all laws and regulations applicable to its business including those relating to human rights and employee rights at work.
Child Labour: The supplier shall comply with all national legislation regarding the employment of children. The supplier shall not employ any children under the age of 15, save as follows. If applicable national laws or regulations allow children between the ages of 13 and 15 to perform light work, such work is not permitted under any circumstances where it would hinder the child from the completion of compulsory schooling or training, or if the employment would be harmful to the child’s health or development.
Forced Labour: The supplier shall not make use of any forced or compulsory labour. The supplier shall not engage in human trafficking or exploitation, or import or use goods tainted by slavery, servitude, forced or compulsory labour or human trafficking. The supplier shall not retain team members government-issued identification, passports or work permits as a condition of employment.
Compensation and Working Hours: The supplier shall comply with all respective national laws and regulations regarding working hours, wages and benefits. The supplier shall ensure that its workers are paid lawful wages, including overtime, premium pay, and equal pay for equal work without discrimination. The supplier shall not make any disciplinary deductions from pay.
Discrimination: The supplier shall not discriminate on the basis of race, religion or belief, disability, age, sex, sexual orientation, gender reassignment, marriage, civil partnership, pregnancy, or maternity. The supplier shall treat its team members with fairness, dignity and respect. The supplier will not perform or tolerate any form of physical, sexual, psychological or verbal harassment or abuse, or victimisation or bullying, within its workforce.
Freedom of Association: The supplier shall respect the rights of workers to associate or not to associate with any group, as permitted by and in accordance with all applicable laws and regulations.
Employment Status: The supplier shall only employ workers who are legally authorised to work in their location and facility. The supplier shall ensure that it validates all employees’ eligibility to work status through appropriate documentation.
Health & Safety
The supplier shall comply with all applicable occupational health and safety regulations and provide a work environment that is safe and conducive to good health, in order to preserve the health of team members and prevent accidents, injuries and work-related illnesses. The supplier shall ensure that all workers receive communication and training on emergency planning and safe work practices. The supplier shall have systems to prevent, detect and respond to potential risks to the safety, health and security of all team members.
Bribery, Corruption and Improper Payments
The supplier shall comply with all international anti-bribery and anti-corruption standards, as stated in the United Nations’ Global Compact, and all local anti-corruption and anti-bribery laws, including The Bribery Act 2010 in the United Kingdom. In particular, the supplier may not offer services, gifts or benefits to Freemans team members in order to influence their conduct.
The supplier shall comply with all applicable environmental laws, regulations and standards.
The supplier shall take steps to implement an effective system to identify and reduce as far as possible any potential hazards to the environment.
The supplier shall strive to support Freemans’ energy efficiency and environmental performance goals through the products and services it delivers. In this regard, the supplier shall take energy efficiency and environmental protection appropriately into account in its own operations, for example, by setting its own energy efficiency and environmental goals and achieving them.
The Supplier’s Business Partners and Chain of Supply
The supplier shall accordingly take steps to ensure so far as possible that it imposes on any such third party its own supplier code of conduct which includes obligations and standards equivalent to those imposed on the Supplier in this Freemans Supplier Code of Conduct.
The supplier shall comply with all relevant tax legislation, shall not engage in any activity, practice or conduct which would constitute unlawful tax evasion facilitation in accordance with the Criminal Finances Act 2017 and shall maintain in place such policies and procedures as are reasonable to prevent the facilitation of tax evasion by associated persons (including without limitation team members).
Compliance with the Supplier Code of Conduct
The supplier will provide all such cooperation as Freemans reasonably requires in order confirming compliance with this Code of Conduct. Freemans therefore encourages suppliers to implementation of their own binding ethical principles and guidelines for ethical behaviour.
We confirm that we have read and will adhere to the Freemans Event Partners Supplier Code of Conduct.
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