INTRODUCTION
The Modern Slavery Act 2015 (‘the MSA’ or ‘the Act’) requires UK companies to promote ethical business practices and policies that protect workers from being abused and exploited in their own organisations and global supply chains. The Act specifically requires all businesses with annual revenues of over £36 million to publish a transparency statement setting out the steps they have taken to ensure there is no modern slavery in their own business and their supply chains.
888 Holdings, which is the Group’s qualifying entity for these purposes, published its first transparency statement to comply with the Act in 2017. This constitutes the Group’s sixth transparency statement, under the Act.
About 888 Holdings
888 Holdings plc(“888”) is one of the world’s leading betting and gaming companies. In 2022, 888 acquired the international (non-US) business of William Hill to create a global industry leader. Headquartered in Gibraltar and listed in London, the Group operates from 12 offices worldwide and employs over 10,000 people globally.
The Group’s mission is to lead the gambling world in creating the best betting and gaming experiences, bringing unrivalled moments of excitement to people’s day-to-day lives. It achieves this by developing state-of-the-art technology and content-rich products that provide fun, fair and safe betting and gaming entertainment to customers worldwide.
The Group owns and operates internationally renowned brands, including 888casino, 888sport, 888poker, William Hill and Mr Green.
The Group is registered with appropriate authorities in the relevant countries in which it has operations, including with the Great Britain Gambling Commission and continues to focus on encouraging responsible gambling and shaping industry best practice. We work closely with customers, sports bodies, and suppliers to help improve the business we operate in.
888 Holdings plc is listed on the London Stock Exchange and is a member of the FTSE4Good Index.
POLICIES
As a Group, we are committed to conducting our operations with honesty and integrity, and with respect for human rights and the interests of our employees and shareholders.
We similarly respect the legitimate interests of those with whom we do business, and who are affected by our operations.
Our Anti Modern Slavery Policy has been approved by the 888 Holdings plc Board and sets out the basic principles that we expect all to comply with across the Group. Our policy operates within a framework to comply with all relevant laws.
ASSESSMENT OF RISK
The Board of 888 Holdings plc remains cognizant of the continuing and emerging risks, impacts and costs of global slavery and human trafficking, and fully supports both the original principles of the MSA. We actively maintain a zero-tolerance approach to slavery and trafficking in all its forms, in any part of its business or supply chain, continuing to apply the UN Guiding Principles on Business and Human Rights and core labour standards set out by the International Labour Organisation.
The ESG Committee of the Board oversees our approach to addressing modern slavery risk and through our well-established governance and risk frameworks, the Board is kept informed of material developments in this area. The Board has approved this Transparency Statement.
The Group Procurement function continue to review and assess the risk of modern slavery in our business and supply chain.We can reaffirm that both 888 and William Hill, its operations and supply chain remain materially ‘low risk’ in terms of both actual instances of, and the potential for, slavery or trafficking. This assessment is based on: the nature of the Group’s businesses, which are focused on retail and online gambling and gaming products and markets; there having been no significant changes to the nature of the Group’s businesses or operations during the year; the robustness of the Group’s people and supply chain policies; and that the majority of the Group’s operations are based in, and, revenues derived from countries deemed low risk by conventional sustainability indices, including The Global Slavery Index (http://www.globalslaveryindex.org/index). We also believe that the Group’s business model is unlikely to create material risks of slavery and trafficking where none existed previously. This is because relatively few raw or manufactured materials are employed in the business, and a significant majority of those working within the business are employed directly by the Group, in line with the Group’s employment policies and practices.
We do however recognise that some of the Group’s operations and supply chains extend into countries deemed to present a somewhat higher modern slavery risk level, according to the Global Slavery Index. Relevant Group functions continue to consider appropriate ways in which risk levels arising in, for example, Philippines, Romania and Bulgaria, can be assessed and mitigated. No matters of concern have been identified to date.
DUE DILIGENCE AND RISK MANAGEMENT
The Group has continued to pursue the introduction of modern slavery preventative clauses within its supplier agreements.
The Group routinely conducts reputational checks, which specifically cover reports of modern slavery, when contracting with new suppliers. Furthermore, prospective suppliers responding to formal tender requests by the Group must confirm their ongoing compliance with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes applicable from time to time.
TRAINING
Training on Modern Slavery and Human Trafficking is available through our e-learning platform and helps ensure the business remains compliant with the Act, as well as mitigates against the risk of modern slavery and human trafficking existing in our business and supply chain.
The training reflects case study examples, as well as procedures related to recognizing and reporting suspected cases. In addition, all of our staff are encouraged to discuss any concerns they may have in relation to Modern Slavery either with their line manager or through the independent Whistleblowing hotline.
2023 ACTIONS
Specific actions taken in 2023 to further strengthen our approach to managing Modern Slavery risk, included the following:
- Reviewed and enhanced a new Anti Modern Slavery Policy for the combined 888 and William Hill Group;
- Continual review of alert driven monitoring across William Hill supply base for any adverse findings;and
- Conducted a full desk-based audit conducted on the Group’s combined supply base to determine a risk rating approach to our suppliers.
FUTURE COMMITMENTS
- To maintain the Group’s zero tolerance approach to Modern Slavery and human trafficking.
- To fully implement alert-driven monitoring of the supply base via 3rd party software to identify any changes in the practices of existing or new suppliers across the combined 888 and William Hill Group.
- To continue to take appropriate action wherever behaviours or activities not consistent with Group policies or values are discovered.
- Implementation of Modern Slavery obligations in all formal tendering as minimum qualification criteria.
TRANSPARENCY STATEMENT
This Transparency Statement is made by 888 Holdings plc in accordance with Section 54(6) of the MSA, for the financial year ending 31 December 2023.
The statement has been formally approved and signed on behalf of the Board of Directors of 888 Holdings on 20 March 2024.
Per Widerström
Chief Executive Officer, 888 Holdings Plc
20 March 2024