Modern Slavery Act 2015

Modern Slavery Act 2015
Slavery and Human Trafficking Statement (“Statement”)

The Scottish Football Association Limited and its subsidiary, Hampden Park Limited (together the “Scottish FA Group”), falls within the scope of the Modern Slavery Action 2015 (“Act”).

This Statement is published in accordance with the requirements of Section 54 of the Act.

The Scottish FA Group is committed to preventing acts of modern slavery and human trafficking from occurring with both its business and supply chains.

Structure, Business and Supply Chain

The Scottish Football Association Limited is the governing body for association football in Scotland.   Hampden Park Limited is the operator of Scotland’s National Stadium, Hampden Park.  The Scottish FA Group derives its revenues largely from the sale of tickets to International and Scottish Cup Competition association football matches, sponsorship, broadcasting, hospitality and payments from international bodies of which the Scottish Football Association Limited is a member.

Generally, its supply chains are short and mainly service based, with the point of delivery of service within Scotland.  Retail merchandising involves the manufacture of goods within the United Kingdom and overseas.

The Scottish FA Group employs FTE 206 people (as at June 2019) and has business operations in Scotland.  The Scottish FA Group turnover to 31^st December 2018 was £37,519,530.

Our Policies on Modern Slavery and Human Trafficking.

The Scottish FA Group is committed to having systems to safeguard against modern slavery existing within our business and supply chains.  The Scottish FA Group has robust employment contracts, employment-related policies and procedures, and recruitment procedures in place which are updated regularly.    No form of modern slavery will be tolerated within our business.

A number of the Scottish FA Group’s activities are outsourced: hospitality services, merchandising and stewarding services.  In the context of the whole of the Scottish FA Group’s operations the foregoing areas are considered to be most relevant to  issues surrounding modern slavery and human trafficking.  The Scottish FA Group has a small number of suppliers (providing services in those areas) which are well-established and reputable.  It also has detailed contracts and service agreements.  Therefore, the risk itself is considered to be small.  The Scottish FA Group remains vigilant for any suspected instances of modern slavery and human trafficking across aspects of our business.

Due Diligence Process for Modern Slavery and Human Trafficking

Relevant contracts and service agreements contain provisions requiring compliance with applicable laws and, where relevant, good industry practice.

The Scottish FA Group’s Procurement Department undertakes RFP’s for key suppliers.  The Scottish FA Group reviews its procurement/supplier selection process on a regular basis – including to ensure that the businesses with which the Scottish FA Group works are able to comply within the Scottish FA Group’s ethical standards.   Specifically, tenderers are required to complete a supply chain transparency questionnaire, the responses to which are a material consideration in the progression of such tenders. The Scottish FA Group will review Statements published by our suppliers on the use of forced labour (as they become available) and appropriate contractual objectives/provisions have been introduced to provide greater assurance.

Training

Specific training on the issue of modern slavery and human trafficking has been carried out for those employees considered to be more likely to have an exposure to the issues.  As policies are updated and communicated, the Scottish FA Group will provide and re-inforce training as required.  During the coming financial year, we intend to roll out an e-learning training module for staff across the Scottish FA Group.

Following a review of our actions this financial year, the Scottish FA Group intends to continue its diligence in relation to our business and supply chains.

This Statement is published in accordance with the requirements of Section 54 of the Act for the financial year ending 31^st December 2018.

Approved by the Board of the Scottish FA on 1^st August, 2019