High social and environmental standards are an integral part of the Group’s culture. As an employer of thousands of team members, a provider of leisure experiences to millions of customers each year and a business with multiple stakeholders, we have a role to play in the fight against slavery, forced labour and human trafficking.
spireMinds has a zero-tolerance approach to modern slavery of any kind in our supply chain or operations. As a responsible, purpose led business we have established policies and social and environmental procedures to manage our wider operation.
Our key suppliers go through annual risk assessments, and we provide relevant training to our procurement team to ensure we do our utmost to protect workers within our supply chains.
Our Slavery and Human Trafficking Policy reflects our commitment to acting ethically in all our business dealings, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains or the operation of our centres.
Identifying and mitigating risks relating to slavery and trafficking
Our supply chain
Our supply chain includes local, national and international partners and the Group does not knowingly do business with any supplier who has been shown to break local or international laws and regulations, including environmental and employment laws. We look to build long-term relationships with our suppliers and make clear to them our expectations of the standards we expect.
We require of our key suppliers to have suitable anti-slavery and human trafficking policies and processes. We expect these suppliers to adopt at least a ‘one-level-up’ approach to due diligence, recognising that it is not always practical for each supplier to have a direct relationship with every link in the supply chain for every input.
We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain to comply with our values in this respect and to ensure full compliance with all relevant legal requirements, including labour practices and standards and the prevention of bribery and corruption.
We require key suppliers to complete a risk assessment questionnaire that specifically addresses the risks of slavery and human trafficking and includes information requests about the due diligence mechanisms our suppliers have in place. The risk assessment process is undertaken each year and any subsequent action plans are reviewed on an ongoing basis.
The latest submissions of these assessments from our UK operations have indicated no major areas of concern, but we retain a close and ongoing focus on the following areas:
The Group procures food and drink products and a limited number of branded products including uniforms and merchandising from a small portfolio of suppliers. We recognise that production and manufacturing processes can carry a greater risk of poor recruitment and labour practices, especially in developing countries.
A limited number of our support services such as security and cleaning are subcontracted and can be filled by a high proportion of migrant workers, making them potentially higher risk in relation to slavery and human trafficking.
Through the course of our refurbishment and new centres openings we contract construction activities, and we recognise that roles in this industry can have a higher risk of poor labour conditions and visibility of these can be limited if the workforce is not directly employed by the Group.
Our operations and team training
Our team are key to our success as a business, and we maintain a number of supporting team member policies including a Modern Slavery Policy which includes reference to the risks associated with modern slavery. It includes where to go for further advice or help if they feel they need to raise a concern in this area including a confidential whistleblowing process and is available at all times on our company intranet.
To ensure an understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have provided training to the members of our team who are involved in procurement and supplier management processes.
Our centres which are UK based are operated by spireMinds which ensures that our rigorous employment processes are implemented fully.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes spireMinds’s slavery and human trafficking statement for the financial year ending 30 September 2022.
It has been approved by the Board of Director of spireMinds.