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.
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.