Modern Slavery and Human Trafficking Statement 2018
Olympia Limited, Olympia Management Services Limited, Olympia Car Park Limited and their wider corporate group (“Olympia London, ‘we’, ‘our’, ‘us’”) operate an exhibition and conference centre with car parking facilities at Olympia London, Hammersmith Road, Kensington, London W14 8UX.
This is Olympia London’s third modern slavery statement, made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps Olympia London has taken in relation to minimising modern slavery and human trafficking risk in its operations and its supply chain. This year’s statement highlights the progress that Olympia London made during the 2018 financial year.
Our Approach and Policies
Olympia London remains committed to combatting modern slavery, servitude, forced or compulsory labour and human trafficking in every part of its business and supply chain. Addressing potential ethical and human rights impacts forms part of Olympia London’s objective to conduct business responsibly. The Grand Plan Annual Report highlights the work undertaken in procurement to address modern slavery risk during 2018, demonstrating our overall commitment to our sustainability programme.
This statement sets out Olympia London’s approach to prevent all forms of modern slavery by describing the policy framework, due diligence, monitoring and training implemented. Overall responsibility for managing the risk of modern slavery arising from any of Olympia’s operations lies with the board.
Olympia London’s employees are expected to undertake their roles with integrity, following ethical business practices in line with Olympia London’s approach to corporate responsibility. This includes awareness of the risk of breaches of human rights, including modern slavery, forced labour and human trafficking.
Olympia London is committed to embedding high ethical standards throughout the business and to operating, as a minimum, in accordance with all applicable laws and regulations. Our policies are approved by the executive management team and the board.
We operate the following policies across our business:
• Recruitment Policy
We operate a range of HR policies and procedures to support the recruitment and management of employees in a fair and positive manner.
• Anti-Corruption and Bribery Policy available at http://olympia.london/abc
We take a zero-tolerance approach to corruption and it is our commitment to conduct business in a fair and ethical manner.
• Whistleblowing Policy
We operate a Whistleblowing Policy to encourage employees and those workers directly affiliated with the business to report any suspected wrongdoing, in the knowledge that their concerns will be taken seriously and investigated in confidence.
• Grievance Policy
Our employees have recourse to an internal Grievance Procedure, based on the principles of openness and fairness to resolve any grievance that may arise.
• Procurement Policy
We operate a procurement policy to ensure our services are acquired consistently across the business. This contains a procedure to support employees in achieving best value and minimising risk when procuring goods, services and works. This policy has been revised and updated to include reference to modern slavery.
• Supply Chain Policy available at http://olympia.london/sc
Our Supply Chain Policy sets out the ethical standards we require our suppliers to uphold and specifically addresses modern slavery and human trafficking.
• Sustainable Development Policy
We apply these high standards to our engagement with stakeholders, our approach to managing our environmental impacts, the quality of services and facilities we supply, our employment practices and procurement. Our Sustainable Development Policy and Grand Plan Annual Report reflect a holistic approach to addressing sustainability, including social sustainability that encompasses modern slavery risk.
Due diligence process and Risk Assessment
As an operator of a world-leading venue, Olympia London procures a wide range of goods, services and works to support the delivery of our business strategy. Olympia London considers that the highest potential risk areas in relation to modern slavery are in its supply chain. To mitigate the risks that could be associated with our business and our supply chain, Olympia London has put in place policies, procedures and processes to avoid incidences of modern slavery and human trafficking. We have terms of business that explicitly include reference to modern slavery. Olympia London assesses modern slavery risk with suppliers.
Olympia London has a Procurement Policy to support employees in achieving best value and minimising risk when procuring goods, services and works. This is supported by a Supply Chain Policy which sets out the ethical standards we require our suppliers to uphold and specifically addresses modern slavery and human trafficking.
Reviews of the Procurement and Supply Chain Policies were carried out during 2018 to ensure the inclusion of a reference to modern slavery.
Progress to date
Olympia London is committed to being transparent with suppliers, to operating in a collaborative manner and to improving our suppliers’ understanding of ethical and responsible business. During 2018 Olympia London undertook the following activities:
• Updated our policies to include a new Procurement Policy and Supply Chain Policy to include specific reference to modern slavery forming part of our new business processes.
• Developed a risk assessment tool for our supply chain in order to identify and better understand where the greatest potential risk of modern slavery may occur.
• Developed a new supplier questionnaire that is more relevant to our current business with the aim of interrogating potential high-risk suppliers.
• Completed a review of Olympia London’s standard terms and conditions and contract templates to ensure that they include an express modern slavery clause.
• Updated our Invitation to Tender Document to include specific references to the considerations of modern slavery.
• Provided workshops on modern slavery and human trafficking to senior management and general training to all staff across the business in order to raise awareness.
• Provided a case study to our trade association, the AEV, to help raise awareness of addressing modern slavery risk within the events sector.
Olympia London operates a conference and exhibition centre. It procures products and services from a number of international suppliers.
We are keen to work with suppliers who conduct their business in a sustainable and ethical manner. All our suppliers have to comply with our ethical business policies. During 2018, as part of the procurement review, we developed a supplier questionnaire to include modern slavery which was sent to all current suppliers that were deemed to be high risk. We are in the process of collecting these responses and will report on our findings in our next statement.
Where a supplier has been identified to have modern slavery in their operations or supply chains, we will endeavour to work with them to remediate the situation, unless there is a failing that is so serious that we are left with no other recourse than to terminate the relationship.
To date, Olympia London has not been made aware of any occurrences of modern slavery or human trafficking in our organisation or supply chain. We have not had any incidents to date where any recourse has been necessary to terminate a relationship with a supplier on grounds of modern slavery risk. We will, however, continue to monitor the effectiveness of our revised processes.
Training and Capacity Building
A training programme on modern slavery was delivered in 2018 by a recognised external consultant:
• A workshop on modern slavery was provided to the senior management team.
• A lecture on modern slavery was delivered to staff.
• Additional procurement training was provided to the senior management team to embed the changes made to the procurement processes.
In the year ahead we will continue to raise awareness of modern slavery with our employees and suppliers through workshops and our procurement processes.
Whilst we believe that the risk of modern slavery within our direct operations is low, we recognise the need to set best practice standards for our supply chain and to regularly monitor and evaluate performance. We will be assessing the findings of the modern slavery risk assessments and questionnaires that were sent in 2018.
Olympia London aims to build on the work to date, with the following activities planned for 2019:
• To carry out a full review of our whistleblowing policy, grievance procedure and agency agreements and where appropriate to update these to ensure that any instances of modern slavery or forced labour can be logged without any fear of bullying or recourse. We will also promote the principles in these policies to our key suppliers and provide access to the whistleblowing hotline.
• To monitor the responses to the modern slavery risk assessment and questionnaires sent to existing suppliers who have been identified as possibly having a higher risk of modern slavery. The findings of these assessments will be reported to our Group Finance Director and where necessary further steps will be taken to address any risk identified.
• Following the update of our Invitation to Tender process we will monitor the responses received as part of our new business process and report on the findings in 2019.
• Training will continue to be provided to all employees via external consultants, company intranet and internal information cascade. We have a modern slavery refresher training workshop booked for 2019 for the senior management team and are reviewing other areas where training may be required.
This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 ‘Transparency in Supply Chains’ and constitutes Olympia London’s modern slavery and human trafficking statement for the financial year ended 31 December 2018. This statement has been approved by the Olympia London Board.
Group Finance Director
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