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Modern Slavery Act Statement

Who we are

This statement is made by Virgin Active Limited, the operating company for the Virgin Active business in the UK (“Virgin Active”). This statement is made in relation to the Virgin Active supply chain.

Virgin Active opened its first club in 1999 in Lancashire and has since grown to become a leading health club operator with 45 clubs across the UK, most of which are based in central London. Virgin Active works hard to provide its members with market-leading expertise, superb innovation and the best clubs in the health and fitness sphere.

Sir Richard Branson is one of the ultimate shareholders of Virgin Active. Virgin Active and Sir Richard Branson support the global fight against labour abuse in supply chains and are vocal champions of supply chain transparency.

We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to mitigate against the risk of slavery and human trafficking taking place anywhere in our supply chains.

Our supply chains

Virgin Active has over 1,250 suppliers, providing a wide range of goods and services to assist in the running of our health clubs and office support functions including, amongst others, marketing, finance, IT, utilities, product, operations, consulting/professional and people services. We have a dedicated procurement team and process in place to procure our suppliers of goods and services.

We regularly review our suppliers and determine which ones we believe to be at high risk of slavery or human trafficking appearing in their supply chains. We assess the level or risk by looking at the various factors including the suppliers’ geographical location(s) and the goods or services being provided.  Whilst many of our goods & services are deemed low risk, some are categorised as higher risk e.g. producers of textiles.

Our policy

We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to mitigate against the risk of slavery and human trafficking taking place anywhere in our supply chains.

In addition to managing our own supply chains, we actively encourage our suppliers to proactively manage material labour, social and environmental risks in their supply chains, including taking steps to stamp out slavery and human trafficking.

Due diligence processes

To ensure that all of our suppliers are aware of our policy and are working to achieve best practice, we have established a supply chain compliance programme.

Currently, this involves requiring all suppliers identified as high risk or significant to agree to our supplier code of conduct at the earliest stage of their engagement with us. These relevant suppliers have confirmed they adhere to this code of conduct. Our supplier code of conduct has been in place for many years and we have recently updated it in light of the Modern Slavery Act. We aim to have the revised code of conduct sent to all suppliers by the end of 2017. If suppliers cannot adhere to the code of conduct we ask them to explain which sections they cannot adhere to and why. They must then demonstrate that they are working towards adhering to our code of conduct.

In 2017 we are introducing a questionnaire to be completed for certain suppliers identified as high risk or key to the business. Suppliers may be classed as key suppliers by looking at factors including the type of goods/services provided or the spend level the business has with that supplier. The questionnaire asks specific questions in relation to the code of conduct.  By the end of 2017 we aim to have received completed questionnaires back from 100% of suppliers we have identified as requiring to complete it. Thereafter we will ask for the questionnaire to be completed every two years.

We intend to conduct audits on an ad hoc basis where we identify a supplier as high risk or as a key supplier.  

Based on the information gathered above, we will produce a risk-map of our various suppliers which we will use to understand where the material risks lie and what action we can take to work with relevant suppliers to change business for good.

Non-compliance

If we find a supplier is non-compliant with our policies or code of conduct or provides inadequate information, we will work with the relevant supplier to improve their performance. In cases of material or persistent non-compliance, we may consider terminating the business relationship as soon as we are able.

Staff who do not follow the policy will be given the opportunity to receive additional training. If that member of staff’s behaviour continues, they may face disciplinary action.

Key performance indicators

We will track the following Key Performance Indicators:

  • Percentage of suppliers who have accepted compliance with our code of conduct.
  • Percentage of suppliers who were sent a questionnaire.
  • Percentage of suppliers who completed and returned the questionnaire.
  • Percentage of suppliers where non-compliance issues with the code of conduct were identified.
  • Percentage of the staff involved in procurement who are trained on slavery issues in the supply chain.

Training

We have held sessions and worked closely with those employees particularly involved in procuring goods and services to ensure they are aware of the Modern Slavery Act, understand our policy in relation to slavery and human trafficking and take practical steps to ensure that policy is adhered to. We are planning to extend that approach to other employees focusing on those in head of department positions.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Virgin Active’s slavery and human trafficking statement for the financial year ending 31 December 2016.

Robert B. Cook

UK Managing Director