This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Birmingham Organising Committee for the 2022 Commonwealth Games Limited (“Birmingham 2022”) during the year ending 31 March 2021 to prevent modern slavery and human trafficking in its business and supply chains. This statement has been approved by the Board of Directors of Birmingham 2022.
For the July 2022 update on progress to date, please click here.
This is the third Modern Slavery statement issued under the Modern Slavery Act completed by Birmingham 2022. It outlines the steps we have taken (and continue to take) as a business to prevent slavery and human trafficking in our own operations and supply chains. We recognise that modern slavery is a national and global issue, and we understand our responsibility to prevent, mitigate and remediate where necessary, the risks of human trafficking, forced, bonded and child labour.
Birmingham 2022 is committed to combatting all forms of modern slavery and our commitment to our customers, athletes and stakeholders is very clear; we will always treat people in our business and supply chain fairly. This means we will continually review and improve our policies, practices, and procedures so that we can fulfil these commitments.
This modern slavery and human trafficking statement (the “Statement”) sets out our approach for ensuring that we have implemented effective systems and controls to prevent these risks from occurring in our business and/or in our supply chains.
Organisational structure and supply chains
Birmingham 2022 is an executive non-departmental public body, sponsored by the Department for Digital, Culture, Media & Sport. It is an organisation which is responsible for the strategy and delivery of the 2022 Commonwealth Games, an international multi-sports event, in the West Midlands and selected locations. On 31 March 2021, Birmingham 2022 employed 354 workers with a head office in Birmingham.
Our product and services supply chain, as of the 31 March 2021, was still in the process of being fully procured for the Games. Our contracted suppliers include direct suppliers of goods & services (first tier suppliers), sub-tier suppliers of goods & services (intermediaries) and origin suppliers of goods & services i.e., farm level, raw material extraction, fishing or input provision (origin). By the times of the Games, we expect to have completed approximately 300 procurement lots with the majority of goods and services to be procured in the UK particularly from suppliers in the West Midlands, however production of commodities will likely include countries in Asia and Europe.
Governance and Leadership
The Board which is chaired by John Crabtree, has overall accountability for managing any modern slavery risk and ensuring that the Act is being complied with. The Head of Procurement is responsible for the implementation of Birmingham 2022’s anti-slavery work as they will have oversight of the procurement process where the risk of modern slavery can be identified and managed.
Policies in relation to slavery and human trafficking
In February 2021, we developed and launched the Birmingham 2022 Sustainable Sourcing Code (the “Code”) as part of our commitment to make Birmingham 2022 the most sustainable Games yet. The Code covers our social and environmental principles with which we expect compliance from our supply chain partners. The principles set out in the Code include sharing our commitment to uphold international human rights standards, including those that relate to modern slavery. We believe that sport drives positive social progress; through the power of sport, we can make significant change to people’s lives. Unlocking human potential to help transform society means that human rights must be established as a core value of the Games. This approach permeates the entire Games operation and will be reflected in all areas of the Games.
In the Code, Birmingham 2022 commits to working with suppliers to support any necessary improvements that may be undertaken to ensure Code compliance. We developed the Code in line with the United Nations Guiding Principles of Business and Human Rights so if, through our operations, we have caused or contributed to a negative human rights impact, we shall work collaboratively with our suppliers to ensure the issues are remediated and practices put in place to avoid recurrence. If we then believe that there is both commitment from the Supplier to avoid a recurrence, and the capability for them to do so, we shall usually continue to work with them, providing the breaches do not continue to reoccur. On the rare occasions that we do not believe the supplier is committed to remediation, the OC shall act, which may involve cancelling purchase orders and ceasing to trade in accordance with our contracted terms.
Our policies reflect our commitment to pay employees fairly and properly for their work, act with integrity and ethically in our business relationships and use best endeavours to enforce effective systems and controls across our supply chains.
Our employees are subject to, and benefit from, a wide range of policies including the following:-
- Anti-Bribery and Corruption Policy
- Modern Slavery (Anti-Slavery and Human Trafficking) Policy
- Staff Code of Conduct
- Procurement Policy
- Whistleblowing Policy
All of our policies are subject to an equality impact assessment. The Birmingham 2022 policies can be found on our website here.
All persons working for Birmingham 2022 must comply with our Anti-Slavery and Human Trafficking Policy. This policy sets out the steps we take to reduce the risk of modern slavery and human trafficking in all parts of Birmingham 2022’s business and supply chains. We take compliance with this policy very seriously and any Birmingham 2022 employee who breaches this policy will face disciplinary action. Our Procurement Policy details the actions we take to combat modern slavery and human trafficking in our supply chain and to embed the mitigating controls in our daily operations.
The policies and frameworks that we have in place limit the risk of modern slavery and human trafficking in the workplace and encourage all staff to work and act ethically.
Risk assessment and due diligence
Given the nature of Birmingham 2022’s business, the risk of modern slavery in our supply chain is considered low. However, we are not complacent about this risk and we understand that no part of our business is immune to the risks of modern slavery and human trafficking. Due to the wide range of activities and industries that are required to deliver a successful Games, we take active steps to ensure that our suppliers, consultants, and contractors, throughout our supply chain, are not engaging in any form of modern slavery and human trafficking, tailoring our approach to the risks of the particular industry and supplier.
We will not support or do business knowingly with a company involved in any form of modern slavery or human trafficking.
Before commencing a procurement process, we use a series of key characteristics (such as sourcing geography, industry type, nature of work and supply chain model) to identify the risk of modern slavery to the relevant contract so we can seek to ensure that the subsequent procurement and contract management activity is proportionate.
As a contracting authority defined by and regulated by the Public Contracts Regulations 2015, all our tenders include the Standard Selection Questionnaire (SQ) which includes a mandatory exclusion question regarding compliance with the Modern Slavery Act 2015. We may require proposed suppliers to provide us with evidence of compliance with anti-slavery and human trafficking laws, such as details of workforce conditions in their factories or evidence of the processes they have in place to identify modern slavery risks in their supply chains. We may also require proposed suppliers to complete a specified Modern Slavery Assessment Tool, depending on their risk rating and the evidence.
In our supply contracts and standard terms of business, we have included express terms requiring our counterparties to comply with modern slavery legislation. We require all suppliers to comply with the Modern Slavery Act and our Anti-Slavery and Human Trafficking Policy, to implement procedures for their own personnel as well as their suppliers to ensure there is no slavery or human trafficking in its supply chains, and to notify us if it becomes aware of any alleged or actual incident of slavery or human trafficking in their business or in their supply chain. We have also included provisions in our supply contracts which allow us to inspect and conduct an audit of a supplier’s and its sub-contractors’ premises to monitor compliance with the supplier’s obligations to comply with anti-slavery and human trafficking laws.
In addition, we require all current suppliers to make positive written affirmations that
(i) they do not; and
(ii) their direct supply chain does not endorse enable or facilitate human trafficking or slavery within their business.
All suppliers must provide detailed information on how they are managing and mitigating the risk of modern slavery in both their business and their supply chains. This declaration must be received before a company can be successfully onboarded.
All suppliers are subject to a series of intelligence checks by the West Midlands Police as part of the procurement process that they are required to pass before they can supply goods or services to Birmingham 2022. The checks on the company and its directors and shareholders, conducted by West Midlands Police and other law enforcement agencies, are in place to ascertain if there are any links with criminal activity. Birmingham 2022 is only notified to confirm a supplier has been unsuccessful in passing the checks; we are not informed of the reason for such failure.
Failure by a supplier to comply with the processes described above will lead to an investigation and may result in the supplier’s contract being terminated.
Birmingham 2022 has not highlighted or experienced any modern slavery issues within its supply chain to date.
We operate a whistleblowing policy that enables anyone to raise any concerns and to have those concerns investigated. We also operate an exit interview process which provides staff with another forum to raise any concerns they may have about our working practices.
We confirm the identities of all new employees and undertake employment checks to ensure they have a right to work in the United Kingdom.
Whilst we have identified the risk to be low, we are planning to conduct due diligence within our supply chains and operations to understand whether there is evidence of modern slavery issues, and whether there are adequate controls in place. Based on our risk assessment, we are planning to implement further assessment processes to check the effectiveness of our supplier management practices.
Training on modern slavery and trafficking
As part of our ongoing commitment to understanding the risk of modern slavery and human trafficking, our Procurement staff will be receiving training in this area. We have been working with an external consultancy who have produced a set of recommendations as to how to embed human rights into all aspects of our work. Training in this area will be provided to the relevant departments, particularly for contract managers of our higher risk suppliers. We will also be working with an external organisation to conduct training on best practice, particularly for third party labour procurement as it is an area of high risk for modern slavery and labour exploitation.
Continuous improvement and progress from our previous statement
As part of our ongoing commitment to eliminating modern slavery and human trafficking, we understand and recognise that our own circumstances and those of our suppliers are constantly evolving. The number of employees in our own organisation and the number of confirmed suppliers is due to increase significantly as we move from the strategic phase into the delivery of the Commonwealth Games.
We will continue to review our processes and assessments in relation to modern slavery and human trafficking to ensure they are fit for purposes, as part of our established risk framework, both as an employer and a purchaser of goods and services.
As mentioned above, since January 2021, we have engaged a third-party consultancy to assess our human rights risks and the different stakeholder communities that may be affected and to develop a strategy, in partnership with the Commonwealth Games Federation, with clear recommendations on policies and steps to take to ensure that human rights are respected. Pending the completion of the strategy, we expect modern slavery to remain one of our key salient risks as many of our contracted service suppliers will use temporary labour or sub-contractors to deliver their contracts.
As the Games gets closer to delivery, we will increase the size of our organisation and the number of contracts that have been completed. As more suppliers are confirmed, we will then be able to risk assess their operations and supply chain. We will also be able to dedicate more resource to do so, working with a third-party auditor to verify our processes and provide additional due diligence.
Measures of success for 2021/2022
Our aim remains to mitigate and manage the risk of modern slavery and labour exploitation in our own organisation and in our supply chains. Pending the completion and results of the consultancy assessment, we have set ourselves a set of ambitious targets that are clear measures of success to deliver an effective ethical trading programme for the Games that mitigates and manages the risk of modern slavery in our operations and in our supply chains. As we implement our workplan, our objectives will evolve as we identify new areas of risk and develop response plans as a result.
- Steering group established to oversee ethical trading and modern slavery (with representatives from the Executive Management Team on the group)
- Ethical Trading Manager appointed to manage supply chain risk
- Review and update Anti-Slavery and Human Trafficking Policy
- Review and update the Whistleblowing Policy so that members of the public and non-OC staff are able to report
- Proactively engage with GLAA and a relevant victim support charity to ensure that the remediation procedure is robust, which will be integrated into our incident management processes
- Publish a supplier list
- Develop a defined labour protocol for suppliers using temporary labour and 3rd party labour providers
- Pilot a defined labour protocol audit
- Roll out the amended labour protocol audit to high-risk suppliers
- 3rd party auditors to conduct additional unannounced due diligence checks to ensure processes are accurately capturing risk
- 100% of procurement lots to have been risk assessed and verified by a third-party auditor
- All medium and high risk suppliers to have provided additional information, detailing their processes and controls to manage their modern slavery risks
- All high risk suppliers to have a relevant audit in place
- 22 additional due diligence checks to have been conducted by Games time
- All procurement staff re-trained on modern slavery requirements
- All managers, responsible for high risk procurement lots, trained on modern slavery requirements so can spot and highlight any red flags to ethical trade manager
- All suppliers identified as higher risk provided with training, run with an external organisation, on best practice in labour procurement
- Engage with an anti-slavery organisation to conduct an awareness-raising campaign
- Identify key stakeholders in the local area and engage them to gain information on current areas of risk for labour exploitation
- Ensure that the Games time incident reporting system will record alleged and actual modern slavery incidents
- Develop a tracker to monitor any alleged or actual modern slavery incidents, either in the organisation or in our supply chains, and track resolution
Birmingham 2022 will conduct an annual review of this Statement and the actions it takes to combat all forms of modern slavery and human trafficking in its supply chain. This statement was last reviewed and updated in November 2021.
This statement was signed by Birmingham 2022’s Chairman, John Crabtree, on 8 December 2021.
Birmingham 2022 Organising Committee’s financial year extends from 1st April 2021 to 30th September 2022 due to the nature of the Games and as such, the organisation is not legally obligated to publish a Modern Slavery Act statement until after this date. As part of our commitment to human rights, it is important to provide visibility of what has been undertaken to manage and mitigate the risk of modern slavery to date. The following table is an informal update on our progress, based against our measures of success that were set out in the 2020/21 statement.
|Measure of success
|Steering group established to oversee ethical trading and modern slavery (with representatives from the Executive Management Team on the group)
|The Steering Group was created in December 2021 and meets every 6-8 weeks. The Chief Financial Officer, Chief Legal Officer, the Director of Programme Management & Integrated Planning, Head of Procurement, Head of Sustainability, Media & PR Manager and CGFP Strategy and Planning Senior Manager are required attendees. The purpose of the Group is to have oversight of and provide direction on the work being undertaken to deliver the ethical trading aspects of the human rights strategy as well as efforts to manage and mitigate the risk of modern slavery in our organisation and our supply chains.
|Ethical Trading Manager appointed to manage supply chain risk
|The Ethical Trading Manager has been in role since October 2021, reporting to the Head of Procurement.
|Review and update Anti-Slavery and Human Trafficking Policy
|The policy was revised to reflect changes in processes and recognise the Ethical Trading Manager role as part of the efforts to tackle modern slavery.
|Review and update the Whistleblowing Policy so that members of the public and non-OC staff are able to report
|The Whistleblowing Policy has been reviewed and updated to ensure that all have access.
|Proactively engage with GLAA and a relevant victim support charity to ensure that the remediation procedure is robust, which will be integrated into our incident management processes
|We have proactively engaged with the GLAA and other modern slavery experts, including the West Midlands Anti Slavery Network, to ensure that we are learning from best practice. During Games time, we have agreed with the Modern Slavery Co-ordinator for Birmingham City Council to work together if potential victims are identified. The co-ordinator will serve as the first point of contact for the OC because they are ideally placed to have visibility of relevant services and what is required for referrals e.g. police referral. This agreement will also include engaging directly with a victim support charity to ensure that victims are appropriately supported throughout the process.
|100% of procurement lots to have been risk assessed and verified by a third-party auditor
|The Organising Committee has approximately 900 first-tier suppliers, who directly have supplied or currently supply us with goods and services. This number includes our engagement with individual consultants and includes contractors for one-off services such as event photography. As this number includes all suppliers, even where it was a low value purchase, we have prioritised efforts with the higher-value and higher-risk procurement lots. All suppliers, regardless of spend, have to sign a declaration of compliance with the 2015 Modern Slavery Act.
All procurement lots (approximately 260 lots) have been risk assessed and verified by PwC. The risk assessment examined the industry of the procurement lot and used the following criteria: supply chain transparency risk, skill level of workforce, presence of migrant/ seasonal/ temporary or casual labour, the use of third-party labour procurement and other key industry characteristics that negatively affect workers. Once a supplier has been confirmed, there is an additional risk assessment completed to understand how that individual supplier is affected by industry risk and what controls that they have in place.
|Publish a supplier list
|In line with our standard financial reporting, all expenditure over £25,000 is now published on our website with the supplier name, a short description of the activity and sum. This is regularly updated and can be found here.
|3rd party auditors to conduct additional unannounced due diligence checks to ensure processes are accurately capturing risk
|The Games has worked with an external human rights consultancy to understand its priority human rights risks and to identify an action plan to strengthen its due diligence plan. This work identified modern slavery as a key area of focus due to the number of industries required to host a successful Games. The OC appointed PwC in July 2021 to design and conduct additional due diligence checks to ensure our processes are accurately capturing risk.
|Develop a defined labour protocol for suppliers using temporary labour and 3rd party labour providers
|The Sustainable Sourcing Code outlines the requirements that we have for all of our supply chain, including that of contractors and suppliers ensuring that their suppliers are complying with these standards through their own audit and monitoring programmes. To support this work, we have engaged with an external consultant to create a suite of template documents that reflect best practice on service level agreements, recommended questions for second-party audits of labour providers and other areas that would highlight the risk of modern slavery.
|Pilot a defined labour protocol audit
|A labour protocol audit was piloted with an established supplier providing cleaning services to the Games Headquarters. The audit identified robust processes and examples of best practice embedded in the company, particularly around worker engagement and welfare. The pilot concluded the audit methodology had limitations and an alternative approach was required.
|Roll out the amended labour protocol audit to high-risk suppliers
|The pilot identified that more information was required for the selection of higher risk suppliers for assessments. While there are risks inherent to certain industries e.g. the presence of third-party labour providers, we had not collected data that showed whether a supplier was using third-party labour providers. A survey was issued in March 2022 to suppliers across higher-risk sectors to assess prior use of labour providers, if they were being used to fulfil the contract and what policies they had in place.
|All medium and high risk suppliers to have provided additional information, detailing their processes and controls to manage their modern slavery risks
|Suppliers are required to sign a Declaration of Compliance with the 2015 Modern Slavery Act, stating their commitment to mitigating the risk of modern slavery risks and what steps that they are taking.
|All high risk suppliers to have a relevant audit in place
|The OC engages suppliers from multiple sectors so what is considered a relevant audit or assessment will differ, depending on whether the supplier is providing a service or a commodity.
Sites that were manufacturing uniforms and branded merchandise were required to complete a factory declaration form and provide a valid independant social audit report for each site of production. Each report was reviewed by the Ethical Trading Manager, a human rights consultant or member of the Sustainability team and non-compliances were noted before approval was given. A tracker was created to monitor non-compliances and their closure.
Service suppliers in higher risk industries were sent a questionnaire by the OC to assess exisiting labour procurement policies, presence of grievance mechanism, knowledge of third-party labour providers and whether they intended to use it to fulfil their Games contract. We were then able to identify if they were high risk and required an additional assessment, whether that was a more detailed questionnaire on their labour providers or a full assessment, which is detailed below.
|22 additional due diligence checks to have been conducted by Games time
|25 additional due diligence checks have been conducted to date. As the risks around human rights and modern slavery may present differently between manufacturing suppliers, which tend to be internationally based, and service suppliers based in the UK, we have adapted our due diligence checks to reflect this difference. The additional due diligence checks were also used to identify whether the OC processes were effect in capturing risk and confirming that information provided by suppliers was accurate. Of 57 manufacturing sites across uniforms and branded merchandise, 8 were selected for an additional due diligence check, which represents 14% of sites. From 143 service suppliers, 17 (12%) had an additional due diligence check.
|All procurement staff re-trained on modern slavery requirements
|All members of the Procurement team (13 in total) were re-trained in February 2022 on modern slavery requirements as well as how to identify higher-risk procurement lots where there may be a need to involve the Ethical Trading Manager.
|All managers, responsible for high risk procurement lots, trained on modern slavery requirements so can spot and highlight any red flags to the ethical trading manager
|171 members of the Organising Committee have received training on spotting signs of modern slavery and labour exploitation as part of their safeguarding training sessions. The training was prioritised for Workforce managers and deputies, who serve as the HR and safeguarding leads at each venue, as well as our Event Services team, who lead our front of house operations as well as the check-in of employees, volunteers and contractors each day. As these are roles closest to spectators and our workforce, including workers who may have been provided through third-party labour providers, it is vital that they are aware of the signs so that they can flag concerns to the Safeguarding Triage Team.
24 workforce managers and deputies attended a further session, facilitated by external modern slavery consultants, that worked through potential modern slavery scenarios in order to familiarise themselves with how issues may present.
|All suppliers identified as higher risk provided with training, run with an external organisation, on best practice in labour procurement
|A free session on modern slavery was provided in June 2022 for suppliers around spotting the signs and managing any concerns. A recording and the slides has been uploaded to an OC contractor portal that is accessible to the employees of 130 contractors, in order to increase access to free expert guidance.
|Engage with an anti-slavery organisation to conduct an awareness-raising campaign
|It's A Penalty is a charity that aims to end modern slavery and exploitation through awareness-raising campaigns, often run at major sporting events. The campaign in Birmingham has been endorsed by United by Birmingham 2022, the official legacy charity of the Birmingham 2022 Commonwealth Games. The deputy chair of the Organising Committee Board, Professor Geoff Thompson, was the keynote speaker at the Birmingham campaign launch on 29th June 2022.
|Identify key stakeholders in the local area and engage them to gain information on current areas of risk for labour exploitation
|The West Midlands Anti-Slavery Network is the local network of stakeholders. The quarterly meetings include representatives from councils, police, health services and third-sector organisations. The Ethical Trading Manager has attended these meetings since January 2022. He also made a presentation to the West Midlands Joint Modern Slavery Human Trafficking/ Criminal Exploitation & Missing Board in March 2022 on the Organising Committee's approach. We have also met with members of the West Midlands police responsible for looking at modern slavery and labour exploitation to get further information about trends and what areas of concern should the OC be aware of well as collaboration during Games time.
|Ensure that the Games time incident reporting system will record alleged and actual modern slavery incidents
|As there are overlaps between signs of modern slavery and safeguarding concerns as well as making it easier for concerns to be reported by spectators, volunteers and our workforce, it was agreed that all potential concerns around modern slavery should follow the Safeguarding reporting route. During Games time, the Ethical Trading Manager will be part of the Safeguarding triage team and all other team members have received training on modern slavery.
There are several routes for incidents to be reported. There is a Games incident tracker, a health and safety incident reporting system which will also track any safeguarding concerns and there is a confidential safeguarding form, accessible by a QR code that will be in key locations around all venues, that goes directly to the Safeguarding Triage Team.
|Develop a tracker to monitor any alleged or actual modern slavery incidents, either in the organisation or in our supply chains, and track resolution
|This has been completed and is in use.