Introduction
ATG Entertainment is a global leader in the theatre and live entertainment business. The magic of an outstanding theatre-going 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 International Entertainment Holdings Limited, ATG Entertainment Limited, The Ambassador Theatre Group (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.
Organisation’s Structure
International Entertainment Holdings Limited (“IEHL”) is an international holding group which holds companies that carry out live entertainment and theatre-related activities. ATG Entertainment Limited, The Ambassador Theatre Group (Venues) Limited and ATG London Limited are subsidiary organisations of the parent company IEHL.
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 approximately 10,000 employees worldwide and currently operates in the United Kingdom, the United States 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 (including IT 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 over £50,000 or where such suppliers are below that threshold but present a higher risk, we ask that suppliers complete a self-assessment 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 Third Party Code of Conduct 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 self-assessment process that these suppliers complete plays an important role in allowing us to monitor risk within our supply chains. This is completed prior to such suppliers being engaged.
– 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.
We are committed in ensuring all staff are legally entitled to work in the country they are employed in and that the contract is directly with them.
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 and is required to be repeated.
Our Effectiveness in Combatting 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 use the following Key Performance Indicators to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains.
– Staff training levels;
– Actions taken to strengthen supply chain auditing; and
– Remedial actions taken in response to reports of modern slavery (if appropriate).
Staff Training Levels
Training has been issued to all permanent staff in line with our annual training programme. This training is repeated annually.
In addition, we have provided extra training this year to those people within the business who manage key suppliers – key account managers. All key account managers have been provided with additional training regarding third party supplier risk management to ensure that they are focused on mitigating risk from use of third party suppliers.
Actions taken to strengthen supply chain auditing
This year, we have rolled out our on-line supplier onboarding process. All suppliers: (i) with whom we spend £50,000/annum or more; (ii) who process personal data; (iii) who present a potential information security risk; or (iv) who present a higher modern slavery risk, are now required to be onboarded through our Third Party Risk Management System (“TPRMS”).
The TPRMS has allowed us to automate processes which were previously manual and imposes stricter protocols on supplier onboarding and on-going management of suppliers. All key account managers have been provided with additional training to recognize risks and assist them with the transition to using the TPRMS for their supplier onboarding.
Using TPRMS is also required as part of any tender process within the business and also allows for new engagements with existing suppliers to be vetted from a compliance perspective as well. Our top 50 existing suppliers have already been re-onboarded onto the TPRMS to ensure that historic suppliers are captured within the system as well as new suppliers.
Remedial actions taken in response to reports of modern slavery (if appropriate).
We have not received any reports of modern slavery this year.
Further steps
We will further embed the TPRMS throughout 2024 and 2025 and monitor the impact. We will also be:
· Providing further training to improve the level of understanding throughout our business
Rolling out TPRMS in our European and US regions to ensure all territories within our business are maintaining high standards of compliance and accountability.
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 the Group General Counsel.
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 2023/2024.
The Boards of International Entertainment Holdings Limited, ATG Entertainment Limited, The Ambassador Theatre Group (Venues) Limited and ATG London Limited approved this statement on 29 October 2024.
Ted Stimpson
Group Chief Executive Officer
29 October 2024
Related Policies Modern Slavery and Human-Trafficking Policy
