UK Tote Group Modern Slavery Statement
Last updated: 9 November 2023
Introduction
The UK Tote Group has a zero tolerance approach to modern slavery of any kind within our operations and supply chain. We all have a responsibility to be alert to the risk of unlawful exploitation of others, however small, in our businesses, in our wider supply chains and in our industry.
At the Tote we are committed to implementing policies and procedures internally and to working with our suppliers and business partners externally to help develop long term solutions with the aim of eradicating modern slavery practices.
Our Business
The Tote was established by Parliament in 1928 as the original pool betting service of Great Britain to provide a safe place to bet and to ensure some of the revenues from gambling were used for “purposes conducive to the improvement of breeds of horses or the sport of horseracing”. Now backed by people from across British horse racing, the UK Tote Group is led by a dedicated group of racehorse owners and breeders and racing fans who are passionate about providing customers with the best communal racing experience and helping to safeguard the financial future of the sport.
Responsibility and integrity have always been at the core of the Tote and as the current stewards of the Tote, we continue to put these values at the heart of everything we do. We set high standards in treating all our colleagues and customers with respect and expect similarly high standards from our business partners, and our suppliers.
Policies and Controls
The prevention, detection, and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control.
A risk management framework has been established by the Tote Risk and Audit Committee ensuring that appropriate policies and procedures have been implemented and are monitored. Our management structure ensures that we can directly implement our policies and procedures, conduct training and monitor compliance and outputs.
In the context of Modern Slavery, the Modern Slavery Policy and supporting procedures at the UK Tote Group provides all colleagues with a first step to avoiding any activity that might lead to, or suggest, any concerns. The Modern Slavery Policy and procedures are supplemented by the other HR policies within the UK Tote Group, including but not limited to the Grievance Policy, Whistleblowing Policy, Equality Diversity and Inclusion Policy to ensure a comprehensive policy suite.
Within this structure we actively support employee engagement, representation, dialogue and the ability of employees to raise potential concerns or grievances. The Whistleblowing Policy and independent Whistleblowing Hotline help ensure that there are no obstacles to exposure or reporting of any unlawful or unethical practices. Performance of the framework and all escalations are then reviewed by the Tote Risk and Audit Committee to complete the cycle.
Supply Chain Mitigation
Mitigation of risk in this area is underpinned by the principle that suppliers must uphold the same high business standards and values as ourselves.
In order to achieve this, before suppliers are selected and onboarded our policies set out to:
establish common minimum standards and other key guidelines to direct procurement activity throughout the lifecycle of an agreement with a third-party;
ensure that the appropriate checks and reviews are conducted, including reviews of processes; and
promote the fair treatment of individuals and third parties.
Where applicable, we require suppliers to provide copies of their own modern slavery statements for review and before the supplier is onboarded.
All suppliers must contract with the UK Tote Group on terms approved by the legal team before services can be commenced. Standard contract terms include a commitment to comply with all applicable law and regulation, including the principles contained within the Modern Slavery Act 2015, meaning that all new suppliers are bound by the requirements of the Act. These terms are then adopted by existing suppliers or partners when they renew their contracts. It has been made clear to all suppliers that any breach of our agreement could result in immediate termination of that contract.
At this stage of our lifecycle, UK Tote Group has a relatively restricted supply chain that is largely characterised by the purchase of IT and technology, software licences, data rights, communications, marketing, and professional services. A key mitigation for the future will be continuing to rationalise and manage our supply chain in this way.
Assessment of effectiveness in preventing Modern Slavery
We recognise that the risk of persons being exposed to exploitation, slavery or trafficking in all of its forms is never static and we will therefore continue to reassess the adequacy of our mitigation practices on an ongoing basis. In the past 12 months we have reviewed and updated our Supplier Management Policy and Process as well as reviewing the adequacy of our Modern Slavery Policy. Enhancements include new supplier categorisation as well as oversight from our Risk and Audit Committee. We have also launched a new employee onboarding process that ensures all our policies and procedures are brought to the attention of new colleagues as soon as they join us.
In the coming year we will continue to maintain oversight over our supply chain to ensure active management of it and, in this context maintain compliance with modern slavery legislation and best practice.
This statement is made on behalf of the UK Tote Group Limited (“the Tote”) and is made in accordance with The Modern Slavery Act 2015 for our financial year ending 30 September 2023.
Alex Frost, Chief Executive Officer