This statement is made on behalf of The Jockey Club and relates to The Modern Slavery Act 2015 for our financial year ending 31st December 2022.
The Jockey Club has a zero tolerance approach to modern slavery of any kind within our operations and supply chain. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. Our colleagues are encouraged to report concerns using our Whistle Blowing policy and management are expected to investigate, and where necessary act upon, these concerns.
Our Business and Supply Chain
The Jockey Club has been at the heart of British Racing for many years and today is the largest commercial group in the sport, comprised of four main operating brands, which between them mean we are involved in virtually all aspects of the British Racing Industry.
These are:
- Jockey Club Racecourses – our racecourse arm
- Jockey Club Estates – our training grounds and estate management
- The National Stud – our breeding and educational arm
- Racing Welfare – our charity
We are also unique for a commercial business in that we don’t make profits for shareholders. Instead we invest all profits back into the sport to support its long term health so British racing will continue to be enjoyed by millions for many years to come. The Jockey Club employs over 600 permanent people in various locations across the UK. In addition, there are thousands of temporary workers employed directly or indirectly by our partners and suppliers to service peaks of high demand at major horse racing meetings and other events.
In recent years sustainable and ethical principles have become increasingly important to us which are reflected in our supply chain. Our products and services are predominantly sourced via UK providers. We also have joint ventures with key providers including catering. We expect the joint venture managements to share our intolerance on Modern Slavery and Human Trafficking. E.g. Jockey Club Catering is a joint venture with Compass Group UK, an organisation with an equally strong stance.
Policies & Contractual Controls
Relevant internal policies include Environmental, Health & Safety, Whistleblowing, Equal Opportunities & Dignity at Work, Sustainability Charter, Bullying and Harassment, and Purchasing amongst others and provide a means of raising concerns, and as appropriate redress without fear of reprisal. Our management structure for each site ensures that we can directly implement our policies and procedures, conduct appropriate training and monitor compliance.
The Modern Slavery and Human Trafficking statement is accessible via our Intranet (Racebook).
We draw attention to our Whistleblowing Policy as a way of escalating suspicions. In February 2023, we partnered with Safecall, an independent, anonymous Whistleblowing Hotline and online reporting system, which allows our colleagues to speak up and report concerns to the highest levels, providing an additional route to raise concerns and report wrongdoing.
Supply Chain Due Diligence
Our Group Purchasing Policy requires evidence of a suppliers’ compliance with MSA15. We have had confirmation that our top 80% of suppliers by spend comply with the Act. Our requirement to comply with the Act has been written into our standard terms and conditions as well as larger group contracts meaning that all new suppliers are bound by the requirement as well as capturing current suppliers when they renew their contracts. It has been made clear to all suppliers that any breach of our agreement could result in immediate termination of that contract. We conduct analysis every 6 months to identify any suppliers we have not worked with in the last 24 months, and they are made inactive from our system.
We recognise the importance of effective due diligence in assessing the risk of modern slavery in our operations or supply chains. This is reflected in our commitment to continually seek to improve our existing processes to appropriately manage these risks. We have a central database of all suppliers, which we continue to assess and classify against a risk rating.
Based on this risk, we undertake regular reviews of suppliers and undertake additional random audits of higher risk suppliers.
In addition, every worker who is contracted to work for us is paid above the minimum wage, and food is provided for them at their place of work.
Training & Awareness
As part of our mandatory training requirements, colleagues are required to complete a Business Compliance Essentials e-learning module, which includes information on the types of Modern Slavery, and common signs to look out for.
Assessment of Effectiveness in Preventing Modern Slavery
We understand that Modern Slavery risk is not static and will continue to mitigate this risk on an on-going basis.
In addition, we will review and assess the effectiveness of this Statement annually and take appropriate action, if required.
We will shortly be bringing in a new Supply Chain Management system (NetSuite) which will allow us to communicate with suppliers and ensure accuracy throughout the purchasing process. Suppliers will be required to upload relevant documentation and certificates to the system, and will be automatically prompted when their certificates are due to expire. We will also be able to report on this from the system, which will be an extra check in ensuring compliance is maintained at all times.
This statement is made in accordance with Section 54 (1) of the Modern Slavery Act 2015 for the financial year to 31st December 2022.
I confirm that I am in agreement with the information outlined in this Modern Slavery and Human Trafficking Statement.
Nevin Truesdale
Group Chief Executive
The Jockey Club
Date: 13th June 2023