Tottenham Hotspur Limited Club Anti-Slavery and Human Trafficking Statement
This is the Anti-Slavery & Human Trafficking Policy (the "Policy") of the Tottenham Hotspur group of companies comprising its holding company, Tottenham Hotspur Limited, and all subsidiaries and trading entities including Tottenham Hotspur Football & Athletic Co. Ltd (all hereinafter referred to as "the Club").
The criteria laid out in this Policy will form the basis of the Club's selection and evaluation for all goods and services which the Club purchases, endorses or attaches its brand to and the parties it chooses to operate with.
The Club requires its suppliers, contractors and commercial partners to subscribe to and accept responsibility under this Policy and to ensure that the same standards are adopted in dealing with sub-contractors relevant to the services or goods provided to, or in conjunction with, the Club.
The provisions of this Policy constitute minimum and not maximum standards, and this Policy should not be used to prevent organisations from exceeding these standards.
This Policy applies to all persons working for the Club or on our behalf in any capacity; including employees at all levels, directors, officers, agency workers, casual workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third party representatives and business partners. Companies working with the Club under any arrangement (whether formal or informal) are at all times expected to comply with this Policy, national and other applicable law and, where the provisions of law and this Policy address the same subject, to apply that provision which affords the greater protection.
Failure to rectify serious breaches of this Policy may entitle the Club to terminate its business relationship with the entity or individual in question.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. The Club has a zero-tolerance approach to modern slavery and the Club is committed to acting ethically and with integrity in all its business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in the Club's own business or in any of the Club's supply chains.
The Club is committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery both within our business and through our
supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. The Club expects the same high standards from all of its suppliers, contractors and commercial partners, and as part of its contracting processes, the Club includes an anti-slavery and human trafficking clause and/or a clause setting out the party’s obligation to comply with all Club policies, including this Policy and our Ethical Policy, which are continuously reviewed, updated and approved at board level. Within our supplier and partner agreements, the Club includes specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and the Club expects that its suppliers will hold their own suppliers to the same high standards.
As part of the Club’s efforts to prevent modern slavery, suppliers, contractors and commercial partners are provided with a copy of this Policy and our Ethical Policy as part of their onboarding process and must confirm in writing that their operations, standards and own supply chains align and comply with them. Only once their confirmation has been noted on the Club’s onboarding platform will the suppliers, contractors and commercial partners be able to engage in any form of relationship with the Club.
The Club also expects suppliers and any of their own suppliers or sub-contractors to ensure that they shall not in any way contravene:
• the provisions of the 1956 United Nations Convention on the Abolition of Slavery concerning the exploitation of child labour;
• the Child Labour (Prohibition and Regulation) Act 1986 and the Factories Act 1948 (in so far as they relate to the employment of children) or any child labour laws in the supplier's jurisdiction and in each case as amended or superseded from time to time;
• the Modern Slavery Act 2015; or
• any subsequent legislation which replaces or amends any of the above.
As part of our initiative to identify and mitigate risk, all employees are required to complete the modern slavery training module and are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains. The Club aims to encourage openness and will support anyone who raises genuine concerns in good faith under the Policy and requires any other party bound by this Policy to do the same.
This Policy is published pursuant to section 54(1) of the Modern Slavery Act 2015 and has been approved by Matthew Collecott, Director, on behalf of the Club.