Modern slavery

1. Background
1.1. This policy applies to the GBWR group (GBWR), presently Great Britain Wheelchair Rugby Limited and its subsidiary GBWR Trading Limited; the policy will also apply equally to any additional subsidiary(ies) which may form part of the GBWR group from time to time.
1.2. GBWR is the national governing body of the game of wheelchair rugby union in England, Scotland, and Wales. GBWR has a number of business operations, including wheelchair rugby operations, commercial partnerships, media distribution, ticketing, retail, property development, and community projects.
1.3. Almost all of GBWR’s operations are conducted in Great Britain. For further information about GBWR, its organisational structure, and its operations, see gbwr.org.uk.
1.4. This statement on the modern slavery, anti-slavery, and human trafficking measures implemented across GBWR’s business is made pursuant to section 54(1) of the Modern Slavery Act 2015.
1.5. The term ‘modern slavery’ used in this statement includes slavery, servitude, any type of forced or compulsory labour, and human trafficking.

2. GBWR’s approach to modern slavery
2.1. GBWR is committed to having systems to safeguard against modern slavery existing within its business or supply chain. GBWR has reviewed its operations and supply chain to assess the risk of modern slavery taking place taking into account a number of factors, including the nature of the activities, their location, the sources from which GBWR is supplied goods or personnel, and the risk profile of relevant locations.

3. Operational
3.1. GBWR is committed towards ethical, social, and environmental responsibility within its business. GBWR complies with all applicable labour laws relating to working terms and conditions, including pay, and places great emphasis on the fair and equal treatment of all personnel, including employees, contractors, and volunteers.
3.2. As part of that commitment, GBWR has corporate and personnel policies which help ensure that the business operates in an ethical and responsible way. These include our policies with regards anti-bribery and corruption, whistle-blowing, declarations of interest, and procurement.
3.3. GBWR has robust procedures for recruiting and onboarding casual, temporary, part-time, and full-time personnel, underpinned by appropriate provisions in the relevant contractual documentation.

4. Supply chain and supplier due diligence
4.1. GBWR seeks to partner with suppliers with shared values and expects the supply chain to operate fair and equitable practices, whereby modern slavery is not tolerated.
4.2. GBWR requires all of its suppliers to sign up to a code of conduct which includes a confirmation that the supplier complies with the Modern Slavery Act 2015. This code of conduct is presented to suppliers as part of the onboarding process, or, in the case of suppliers contracted prior to implementation of this policy, at the earliest available opportunity. This onboarding process allows GBWR to assess a new supplier’s policies, procedures, processes, and values before engaging them, or, in the case of suppliers contracted prior to implementation of this policy, at the earliest available opportunity.
4.3. GBWR has also created a comprehensive anti-slavery checklist which is sent to suppliers as part of the onboarding process, which is used to evidence the policies and processes suppliers have in place to prevent modern slavery in their business. Suppliers must complete this checklist before appointment, or, in the case of suppliers contracted prior to implementation of this policy, at the earliest available opportunity.
4.4. The contractual terms and conditions that put in place with suppliers are regularly reviewed with this policy and include provisions designed to ensure that any risks of modern slavery in our supply chain are appropriately and effectively addressed; any material changes to the policy or onboarding requirements will be addressed by requiring the supplier to recomplete the relevant elements of the onboarding process.
4.5. GBWR has undertaken a risk-based approach to assess the likelihood of the existence of modern slavery within its supply chain. This risk assessment is an ongoing exercise for the existing supply chain, as well as for potential new suppliers. The enhanced onboarding process for our suppliers will help GBWR to identify any such risks going forward.
4.6. If a risk of modern slavery is identified within a supplier, GBWR will consider whether it is satisfied that these risks are being appropriately addressed and reserves the right to refuse to continue to use or appoint any supplier whose operations and/or supply chain fails to meet these requirements. Indeed, where GBWR has perceived that a supplier may be exposed to the risks associated with modern slavery, GBWR will request evidence of the measures that such supplier has implemented to combat modern slavery.

5. Reporting and response
5.1. The head of business operations will review all supplier onboarding applications/updates and maintain a register of applications and status. This register will be shared annually with the governance and finance committee and board of trustees.
5.2. The head of business operations will raise any concerns identified during the onboarding process to the CEO; these concerns, where relevant will be raised to the governance and finance committee and board of trustees.
5.3. Any concerns raised outside of the onboarding process should be taken to the head of business operations in the first instance, where they will be escalated as per the reporting lines outlined in the clause above.
5.4. Depending on severity of the findings where a supplier is implicated, GBWR reserves the right to immediately pause any existing activity with the supplier whilst the findings are investigated.
5.5. GBWR will work with the supplier for further understanding and review will be undertaken by the governance and finance committee, which will make a recommendation to the board of trustees.
5.6. If the supplier is found to be in breach of GBWR’s requirements, the board of trustees may decide to temporarily pause activity with the supplier whilst issues are addressed and resolved in a timely manner, or immediately terminate the agreement with the supplier.

6. Future steps and continued commitment
6.1. GBWR ensures this policy is included as part of its induction process for new starters and is readily available for all personnel, members, and the public via its website at gbwr.org.uk.
6.2. GBWR will continue to work with its commercial partners to better understand their processes and policies and to prevent modern slavery within their organisations and supply chains.
6.3. GBWR recognises the importance of maintaining constant vigilance to identify and address any impacts associated with slavery and human trafficking throughout its supply chains, and in continuing to enhance its capacity to identify, prevent, and mitigate any actual or potential impacts in this field.
6.4. GBWR will continue to assess the effectiveness of the measures it takes and will regularly review and refine its policies and procedures in relation to modern slavery.

Approved by the GBWR Board of Trustees at the meeting held 27 September 2023.

To be reviewed by the GBWR Board of Trustees September 2025.