Modern Slavery Statement
This statement is published on behalf of IMG Arena UK Ltd and their subsidiaries (“IMG Arena”) pursuant to section 54 of the UK Modern Slavery Act of 2015. It constitutes our modern slavery and human trafficking statement for the financial year ending 31 December 2022.
IMG Arena is committed to combatting slavery in all forms, including human trafficking, forced labour and workplace abuse. This statement sets out the steps that IMG Arena has undertaken, and is continuing to take, to ensure that slavery and human trafficking do not take place in any part of our business or our supply chains.
Our Business Structure
The IMG Arena business is part of the IMG Group, which forms part of the Endeavor group of companies, whose businesses includes sports, fashion, and client representation. Our ultimate parent company is Endeavor Group Holdings, Inc. (“Endeavor”), which is headquartered in Beverly Hills, California. IMG Arena headquarters are in London, United Kingdom and it operates globally. Its business deals with the supply of betting-related products and services to online and retail sportsbook operators. This includes the collection, integration and distribution of official live data and audio-visual footage from certain sports events.
Our Supply Chain
As a company focused on delivering technology services to sportsbook operators, the risk of modern slavery being present in our supply chain is considerably low. Some of our services are outsourced to third party suppliers which may include logistical support services, IT services and site staff. Where IMG Arena enters into markets that may require additional diligence it will use appropriate measures to guard against any forms of slavery or forced labour in its supply chain.
Our Policies and Procedures
IMG Arena has implemented several policies and procedures, the aim of which are to help ensure that slavery and human trafficking do not form part of our business or supply chains, including:
1. Employee Code of Conduct
All IMG Arena employees are required to act in accordance with the principles set forth in our Company’s Code of Conduct (the “Code”). The Code states that employees have a responsibility to uphold the highest standards of business conduct and ethics, and to speak out if they see or suspect someone of violating these standards, any Company policy, or engaging in any illegal behaviour. Our Company’s Code of Conduct is revised periodically, and was updated in 2021. It includes requirements to follow the principles of fair employment and to review and report human rights violations within our supply chain.
2. The Endeavor Ethics Helpline
Further to the above, Endeavor has established the Endeavor Voice It Helpline (the “Helpline”) to facilitate reporting of potential violations of our Company’s policies or applicable laws. The Helpline provides an avenue for employees and others to raise concerns (anonymously if preferred and where permitted by law) 24 hours a day, 7 days a week in a variety of languages. All information is recorded by an independent third party who then provides the details to an internal investigator to handle as appropriate.
3. Whistleblower Policy
To ensure our commitment to a culture of integrity, IMG Arena has established a Whistleblower Policy (the “Policy”). The Policy affirms that anyone who raises a certain complaint or concern of potential violations of our Company’s policies or applicable laws is protected and retaliation is strictly prohibited.
4. Third Party Due Diligence
IMG Arena requires that vendors and suppliers in high-risk jurisdictions undergo a due diligence screening process to identify public records indicating a history of bribery or corruption or other indications of illegal activity. This screening protocol has been implemented across the majority of our Company’s business units and is designed to detect risk factors such as application of sanctions, involvement of politically exposed persons, and publication of adverse news media reports, including reporting regarding any involvement with slave labour or human trafficking.
5. Contractual Obligations
IMG Arena incorporates into its contracts an obligation for contracting parties to comply with all applicable laws, including the Modern Slavery Act where applicable. In addition to the standard contractual obligations, IMG Arena requires certain high risk third-parties to review and agree to a Third-Party Code of Conduct which includes requirements to comply with labour and human rights laws as well as the principals of fair employment.
In 2022 IMG Arena plans to provide refresher training on modern slavery, including how to identify possible instances of forced labour or workplace abuse and reporting steps where such activity may be taking place to relevant employees.
7. Looking Ahead
Over the course of the next financial year we will continue to review our procedures to help us identify, prevent and mitigate any risks of modern slavery or human trafficking in relation to new and existing suppliers and in relation to our own operations, including continued review of the obligations we require of our suppliers and training where appropriate.
This statement has been reviewed and approved by the Board of Directors of IMG Arena UK Ltd.