Genius Sports Group Limited
Modern Slavery Act 2020/ 2021 Statement
Our Business and Organisation
Our Supply Chain
Due Diligence Processes
- Identify and assess potential risk areas in our supply chain
- Mitigate the risk of slavery and human trafficking occurring in our supply chain
- Monitor potential risk areas in our supply chain
- Protect whistle blowers
We have a dedicated team which consists of representatives from the following departments:
- Legal Tom Russell, General Counsel
- Procurement: Helen Taylor, Operations Director
- Finance: Iffy Obadeyi, Financial Director
- Requesting a copy of their Modeern Slavery Statement
- Confirming compliance with the annual reporting requirements per Section 54
- Conducting audits on new suppliers that fall into high-risk categories (normally by meeting at RFP stage; prior to appointment) – enquiring into their operations, how they source labour and materials, the prices they pay to suppliers beyond tier 1 further down the supply chain and their sub-contractors etc.
In 2020, we undertook a number of measures to ensure we were effectively monitoring the labour and ethical standards of our suppliers and to ensure, to the best of our knowledge, that slavery and human trafficking is not taking place within our supply chain:
- All new suppliers onboarded in 2020 had to meet labour and ethical standards criteria as part of our due diligence; including compliance with section 54 of the Modern Slavery Act.
- We have reviewed and tested various outsourced supplier risk managements systems to assist with our supply chain compliance programme. The system developed for procurement policy and supply chain verification can be tested/audited.
- We have purchased access to 70,000+ pre-stored supplier profiles which include ethical standards and reporting; allowing those in procurement roles to review potential suppliers more thoroughly.
- We have identified high risk suppliers using a triage system.
- We introduced a Sustainable Procurement Statement which is in line with this statement and the United Nations Global Compact Principles. It helps to drives best practice procurement decisions and processes, e.g. ensuring respect of ethical standards.
- Key employees in a procurement role have received training on identifying and addressing the risk of slavery and human trafficking in our business and supply chain.
- Three thorough new supplier appointment interviews were undertaken (for high-risk suppliers appointed during COVID-19) to understand labour sourcing, payment, contracting provisions etc
- Additional reviews of existing suppliers during COVID-19 to understand the provisions for; continuation of employment, health & safety guidance, PPE and sickness management etc.
Following a review of the effectiveness of the steps we have taken this year; we intend to take further steps to combat slavery and human trafficking.
In 2021, we are committed to continuing to develop our approach to Modern Slavery and to ensure that we meet our sustainable procurement objectives. Key measures and objectives we have set out to achieve are:
- All third party and ethical and labour standard risks will be logged in our corporate risk register system.
- We will regularly complete risk assessments on both existing and new suppliers.
- We will map the source-to-pay process end to end including escalation pathways for concerns.
- We will introduce a new anonymous whistleblowing hotline which is aimed principally at our
employees, but also available to suppliers that encourages the reporting of any wrongdoing.
- Develop an enhanced procurement learning programme with those involved in the supplier risk
Genius Sports Group Limited
16th December 2020
Date of next review: 16th December 2021