Background
This statement is made on behalf of the Rugby Football Union. References to "we", "us" or "our" in this statement are to the Rugby Football Union.
The Rugby Football Union is the governing body of the game of rugby union in England. We have a number of business operations, including rugby operations, commercial partnerships, media distribution, ticketing, retail, property development and community projects.
Almost all of our operations are conducted in the UK. For further information about the Rugby Football Union, its organisational structure and operations, see: https://www.englandrugby.com/about-rfu
This statement on the anti-slavery and human trafficking measures implemented across our business is made pursuant to section 54(1) of the Modern Slavery Act 2015.
The term “modern slavery” used in this statement includes slavery, servitude, any type of forced or compulsory labour and human trafficking.
Our Approach to Modern Slavery
The Rugby Football Union is committed to having systems to safeguard against modern slavery existing within our business or supply chain. We have reviewed our operations and our supply chain to assess the risk of modern slavery taking place taking into account a number of factors, including the nature of our activities, their location, the sources from which we are supplied goods or personnel and the risk profile of relevant locations.
a) Operational
The Rugby Football Union has had a long-standing commitment towards ethical, social and environmental responsibility within its business. We comply with all applicable labour laws relating to working terms and conditions, including pay, and we place great emphasis on the fair and equal treatment of all our staff.
As part of that commitment, we have corporate and people policies that help us ensure that our business operates in an ethical and responsible way. These include our Procurement Policy and associated guidance, Asylum & Immigration Policy, Anti Bribery & Corruption Policy, Speak Up Policy, Whistleblowing Policy, Gifts & Hospitality Policy and Conflicts of Interest Policy.
We have robust procedures for recruiting and onboarding casual, temporary, part-time, and full-time personnel, underpinned by appropriate provisions in the relevant contractual documentation. Mandatory business governance training is in place for employees.
b) Supply Chain and Supplier Due Diligence
We seek to partner with suppliers that share our values, and we expect our supply chain to operate fair and equitable practices, whereby modern slavery is not tolerated.
We expect all our suppliers to sign up to a Code of Conduct which includes a confirmation that they comply with the Modern Slavery Act 2015. This Code of Conduct is presented to suppliers as part of our onboarding process. This onboarding process allows us to assess a new supplier’s policies, procedures, processes and values before engaging them.
We have a comprehensive anti-slavery checklist which is sent to suppliers as part of the onboarding process, which is useful to evidence the policies and processes that suppliers have in place to prevent modern slavery in their business. Suppliers must complete this checklist before we appoint them.
The contractual terms and conditions that we put in place with our suppliers are regularly reviewed and include provisions designed to ensure that any risks of modern slavery in our supply chain are appropriately and effectively addressed.
The Rugby Football Union has undertaken a risk-based approach to assess the likelihood of the existence of modern slavery within our supply chain. This risk assessment is an ongoing exercise for our existing supply chain, as well as for potential new suppliers. The enhanced onboarding process for our suppliers will help us to identify any such risks going forward.
If we identify a risk of modern slavery within a supplier, we will consider whether we are satisfied that these risks are being appropriately addressed and we reserve the right to refuse to continue to use or appoint any supplier whose operations and/or supply chain fail to meet our requirements. Indeed, where we have perceived that a supplier may be exposed to the risks associated with modern slavery, we have requested evidence of the measures that such supplier has implemented to combat modern slavery.
Reporting
We have a dedicated Procurement team which, in addition to our wider Finance team, helps to identify potential risks regarding slavery and human trafficking. Where a supplier is implicated, we will engage with the relevant supplier(s) and implement an appropriate and timely response. This may include the immediate termination of the supply agreement.
Future Steps and Continued Commitment
We will continue to work with our commercial partners to better understand their processes and policies and to prevent modern slavery within their organisations and supply chains.
The Rugby Football Union recognises the importance of maintaining constant vigilance to identify and address any impacts associated with slavery and human trafficking throughout its supply chains, and to continuing to enhance its capacity to identify, prevent and mitigate any actual or potential impacts in this field.
We will continue to assess the effectiveness of the measures we take and we will regularly review and refine our policies and procedures in relation to modern slavery.
Approved by the Board of Directors of the Rugby Football Union on 8 January 2024
