Modern slavery is a heinous crime and 888 Holdings Plc and its subsidiaries (the "Group"/we) believe that businesses have a vital role to play in tackling the issue. The Group is dedicated to creating a corporate culture where business is conducted with honesty and integrity and everyone is treated with dignity and respect. It is for this reason that the Group has zero tolerance for, and is committed to ensuring that it is not complicit in, any forms of slavery, servitude, forced labour and human trafficking ("Modern Slavery"). Similarly, we expect the same commitment from all of our employees, contractors, suppliers and other business partners.
This statement has been published pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement for the Group for the financial year ending 31 December 2022. It has been approved by the Group’s Board of Directors and will be reviewed annually to ensure its effectiveness and to ensure the Group’s continued adherence to the active eradication of any form of Modern Slavery in its direct operations and in the indirect operations of its supply chain.
The Group has decided that it will ensure, as a matter of Company policy, in all of its internal workings as well as business with its suppliers, that relevant checks and balances are implemented, to prevent any form of Modern Slavery. It has created a specific policy and related supporting procedures to ensure this policy is implemented and upheld.
As part of the adoption of such an Anti-Modern Slavery Policy, the Group has determined and is implementing various risk assessment measures to prevent Modern Slavery practices both in its operations and through its supply chain (including, but not limited to, the provision of a letter to suppliers outlining the Group’s policy, inclusion of relevant representations and provisions in supplier contracts and satisfactory completion of a due diligence questionnaire if deemed required in the circumstances).
In 2017, the Group initiated a risk assessment of its supply chain to check where any possible risk areas may exist, in terms of Modern Slavery. Whilst the Company is an entertainment business and, in general, our workforce is highly skilled due to the technical and highly regulated nature of our offering, and we have a relatively small supply chain compared to other businesses, particularly due to an emphasis on our online presence, the Group felt it necessary to nonetheless conduct this important risk assessment. Additionally, the Group constantly ensures its employee and supply contracts are prepared and checked by local legal counsel, to ensure adherence to important local laws and regulations in the various jurisdictions in which the Group has a business presence.
Additionally, we have a Whistleblowing Policy in place to ensure that our employees and contractors can voice any concerns about Modern Slavery without fear of repercussion. The Group also has a detailed Anti-Bribery and Corruption Policy which provides relevant guidelines and procedures to employees about the importance of ensuring an honest and ethical business and appropriate engagement with third parties, including agents and suppliers.
Training, awareness and monitoring
This statement will be periodically disseminated to employees and will be available on the Group’s website and intranet. The Group’s company secretary has been charged with identifying relevant staff to whom specialised training in such matters will be conducted (specifically those involved in the Group’s supply chains) and such training was rolled out in 2018. We commit to continually reviewing our business and supply chain to identify any areas which may be at risk of contravening the Modern Slavery Act and take the necessary steps to mitigate any risks identified. This statement has been approved by the Group’s Board of Directors and is signed by our Chief Executive Officer on its behalf.
CEO 888 Holdings Plc