Modern Slavery Act 2017
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 43 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 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 a large number of 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. Over the past 12 we have reduced the number of suppliers we engage with. 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 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 as higher risk e.g. producers of textiles.
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 , 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.
We have a supplier code of conduct in place, and we require all of our suppliers to agree to it at the earliest stage of their engagement with us. During 2017, we sent our code of conduct to all suppliers with whom we had had in the previous 18 months (1,214 suppliers in total) requiring them to comply with it and requesting that they respond with any concerns or difficulty complying with the code of conduct. No suppliers responded raising any concerns or compliance issues. Our supplier code of conduct has been in place for many years and was updated in 2017 in light of the Modern Slavery Act. 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 introduced 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 we had received completed questionnaires back from all 22 of the suppliers we identified as to complete it. No significant risks or concerns were raised by the questionnaire responses. We intend to ask all high risk and key suppliers to complete the questionnaire every two years, as well as requiring any new high risk and key suppliers to do so.
We 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.
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 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. During 2017, the code of conduct was sent to 100% of suppliers with whom we spend within the previous 18 months with a request that they respond with any concerns or difficulty complying, and none responded to raise such concerns or difficulties.
- Percentage of suppliers who were sent a questionnaire. During 2017, 22 of our total of 1,214 suppliers (1.8%) were sent a questionnaire.
- Percentage of suppliers who completed and returned the questionnaire. During 2017, 100% of suppliers who received a questionnaire completed and returned it.
- Percentage of suppliers where non-compliance issues with the code of conduct were identified. During 2017, no non-compliance issues were identified with the code of conduct.
- Percentage of the staff involved in procurement who are trained on slavery issues in the supply chain. During 2017, all members of the procurement team were trained on slavery issues in the supply chain.
Our procurement team manage our suppliers and the procurement of goods and services for the Virgin Active business and the team members are all 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. Our anti-slavery policy has been communicated throughout the business, but we plan to carry out further awareness-raising with employees focusing on those in 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 2017.