MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT
Ultreso takes its responsibility to society seriously. Doing business with integrity is one of our fundamental corporate values.
The following statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for our financial year (to 31 December 2020).
Organisational Structure
This statement is made solely on behalf of our UK operations; however, we seek to promote high standards throughout our businesses
Our supply chains
The businesses for whom we make this statement operate in the United Kingdom and have a limited supply chain which, we consider gives CEUK a lower exposure to the risks of Modern Slavery.
However, we seek to ensure that companies from which we purchase products and services are operating in an ethical and responsible manner. Our UK supply chain consists of:
- Large and small technology suppliers based in the UK and worldwide
- Live event suppliers based predominantly in the UK
- Print and logistics suppliers based predominantly in the UK
- Food & drink suppliers based predominantly in the UK
- Outsourced Facilities Management based predominantly in the UK (i.e cleaning services, security, pest control, building maintenance, laundry services)
- Goods suppliers based predominantly in the UK (e.g. catering equipment, furniture, marketing collaterals, stationery, staff uniforms)
- Freelance editorial suppliers based predominantly in the UK
We have ascertained that the main risks we have in our supply chain are:
- the use of agency/outsourced labour
- the use of beverages and food products that are sourced abroad by our suppliers
Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. This anti-slavery statement reflects 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 either internally or in our supply chains.
Due Diligence
We will not tolerate slavery and human trafficking. Most of our supply chain we regard as relatively low risk. However, our Procurement and Contract Management Policy requires us to consider where the risks may be greater and to prioritise those risks. For example, risks may be higher in certain jurisdictions and in respect of lesser skilled labour. In such riskier circumstances, we will require a Risk Assessment Questionnaire to help us better understand the risks. Direct suppliers in higher risk categories will also to be given our “Supplier Code of Conduct” to which Caesars Entertainment expects adherence. Where a supplier will not or cannot adhere to these requirements our relationship will be reviewed and Caesars will consider terminating our relationship.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff.
We have launched a training video on Modern Slavery for all our team members to review on our learning portal. All Key members of our HR and Procurement Teams are expected to undertake this training.
We consider ourselves a low risk in terms of Modern Slavery. However, we have a range of HR policies and procedures which collectively assist us in ensuring that we can meet the objectives of this statement and provide additional safeguards. Principally, these are:
- Harassment & Bullying Policy
- Grievance Procedure
- Equal Opportunity Policy
- Whistle Blowing (dedicated 0800 number)
Our effectiveness in combating slavery and human trafficking
We discuss with other Casino operators as well as hospitality companies to discuss our approach and share best practice. We will review any updated advice from CIPS (Chartered Institute of Procurement and Supply) and HM Government on how to identify and mitigate risks. The Board will receive an annual report which will highlight our effectiveness or otherwise in meeting our objectives.
We will endeavour to get further insight into our supply chain through prequalification and understanding our suppliers’ supply chains. The Board of Directors have considered and approved this statement.
If you want more information contact us at compliance@ultreso.com