ATG modern slavery and human trafficking statement
The Ambassador Theatre Group is a global leader in the theatre and live entertainment business. The magic of an outstanding theatregoing experience is at the heart of everything that we do and we are passionate about offering our customers the highest quality performances together with exceptional service. As part of this, we are committed to running our operations responsibly and combatting modern slavery and human trafficking.
This statement is published on behalf of The Ambassador Theatre Group Limited, ATG Venues Limited and ATG London Limited (“ATG”) pursuant to the Modern Slavery Act 2015 (“Act”). References to “we”, “us” and “our” are references to ATG.
ATG owns and manages premium live venues around the world, is an internationally recognised award-winning theatre producer and a leader in theatre ticketing services. ATG has over 3,500 employees worldwide and currently operates in the United Kingdom, the United States, Australia and Germany.
Our supply chains include: providers of leasehold property, providers of food and drinks to our venues and providers of facility management services (e.g. cleaning) as well as IT and other business support services.
Further information about ATG can be found in the “About Us” section of our website: http://www.atg.co.uk/about-us/
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery (which is defined in the Act as “slavery, servitude and forced or compulsory labour”) or human trafficking in our supply chains, or in any part of our business. Our ATG Code of Conduct reflects our commitment to acting ethically and with integrity in all our business relationships, and to ensuring that slavery and human trafficking is not taking place anywhere in our supply chains.
Operating within ATG’s value system and a principled approach to doing business is one of our key business aims. As set out in our ATG Code of Conduct, we seek to incorporate the UN Global Compact’s Ten Principles into our strategies, policies and procedures to set the stage for long-term success. Principle one is “the protection of internationally proclaimed human rights” and principle four is “the elimination of all forms of forced and compulsory labour”. Our ATG Code of Conduct sets out our commitment in respect of human rights and makes clear that modern slavery is not condoned by us. This ATG Code of Conduct is provided to all employees and is made available to customers on our website.
We have a dedicated compliance team, which consists of representatives from the following departments: Legal, Human Resources, Procurement and Finance. Our compliance team are responsible for monitoring ATG’s supply chains and liaising with suppliers on matters of modern slavery where appropriate.
SUPPLIER ADHERENCE TO OUR VALUES
We seek to partner with suppliers that have a policy of zero tolerance to slavery and human trafficking and adopt the same standards that we adhere to in order to prevent such activities. To ensure that this happens, we use a risk based approach to assess each supplier’s activities prior to appointing them. In doing so we consider the origin of manufacture of any goods that will be provided to us and the nature of and location from which goods and services are provided. This allows us to identify potential areas to assess for modern slavery risks.
In the event that we became aware of an incident of modern slavery or human trafficking in our supply chain, we would work with the supplier to implement a remedy as soon as possible and consider whether it would be appropriate to terminate the arrangement.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
In order to identify and mitigate areas of risk in respect of modern slavery and human trafficking in our supply chain, we have primarily focussed on operations managed from our UK offices. This process has included an analysis of our supply chain, a review of our internal business processes and an analysis of the third parties that we currently contract with. We continue to monitor and strengthen our systems which helps us to identify and assess potential modern slavery risk areas within our supply chain. Our systems help us to:
– Identify and assess potential modern slavery risk areas in our supply chains For all supplier contracts that we identify as higher risk, we ask that suppliers complete a selfassessment form in which they set out the procedures that they have in place to prevent modern slavery and human trafficking from occurring in their supply chain. We also provide suppliers with a copy of our modern slavery and human trafficking policy, and ask that they commit to maintain the standards that we require from all our suppliers with regards to the ethical obligations that are owed under the law.
– Monitor potential risk areas in our supply chains We continue to focus on areas in our supply chains that we identify as higher risk, and the selfassessment form that these suppliers complete play an important role in allowing us to monitor risk within our supply chains. This is completed prior to such suppliers being engaged. For completeness, we are also rolling this process out to lower risk areas in our supply chains so that we can confirm that these suppliers have satisfactory processes and policies in place, and that we have appropriately categorised them as presenting a lower risk.
– Protect whistle blowers who inform us of any potential issues Our whistleblowing policy clearly sets out how a member of staff may raise any concerns that they have if they believe that they have identified an instance of modern slavery or human trafficking in our organisation or supply chain.
In addition to our whistleblowing policy, our ATG Code of Conduct and modern slavery and human trafficking policy set out our expectations of our staff’s conduct and set out their ethical and legal obligations. As these are some of our key policies, they are included in our employee handbook and are a permanent fixture on our intranet.
Lastly, we continue to ensure that all permanent staff are trained in this area. This training is also a part of all new employee’s induction course.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
In order to combat modern slavery and human trafficking, we understand that our efforts need to be ongoing and improved upon year on year. To assess the effectiveness of the measures taken by us to prevent modern slavery and human trafficking, we will continue to review our Key Performance Indicators and report on them in future modern slavery statements.
– Staff training levels; – Actions taken to strengthen supply chain auditing; and – Remedial actions taken in response to reports of modern slavery (if appropriate).
MONITORING AND REPORTING
If we become aware of an actual or suspected instance of modern slavery or human trafficking occurring in any of our supply chains, we will work to resolve the issue through legitimate and proportionate measures.
Any significant problems identified in relation to modern slavery should be immediately reported to Head of Legal.
General issues in relation to management of modern slavery should be reported back to the Board on an annual basis.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes ATG’s slavery and human trafficking statement for the financial year 2019/20.
The Boards of the Ambassador Theatre Group Limited, ATG Venues Limited and ATG London Limited approved this statement on 24 September 2019.
Group Chief Executive Officer