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Anti-Slavery and Human Trafficking Statement

West Bromwich Albion Football Club Limited (hereinafter the “Club”) is committed to eliminating the existence or prospect of modern day slavery and human trafficking within its own business and that of its supply chain, and imposes the same high standards on its contractors, suppliers and all of its other various business partners.
 
The Club acknowledges that it has an obligation to make a slavery and human trafficking statement setting out the steps it is taking to ensure that slavery and human trafficking are not taking place in any of its supply chains or in its own business under the UK Modern Slavery Act 2015.
 
The Club’s structure, business and supply chains
 
The Club is an English professional football club which was established in 1878 playing under the rules and regulations of various governing bodies including (but not limited to) FIFA, UEFA, The English FA the Premier League and the Football League. 
 
The Club is a registered limited company (with the registered company number 03295063) and is under the ultimate control of Yunyi Guokai (Shanghai) Sports Development Limited. 
 
The Club’s supply chain is comprised of the external organisations that provide the products and services the Club purchases, including (but not limited to) providers of food and beverage products, cleaning services, merchandise for re-sale, playing kit, security personnel and other equipment and services.
 
Policies in relation to Slavery and Human Trafficking
 
The Club does not support or knowingly deal with any business involved in slavery or human trafficking.
 
The Club has a specific Anti-Slavery / Human Trafficking Policy and Whistleblowing Policy which reflects its commitment to acting ethically and with integrity in all of its business relationships and to implementing and enforcing effective systems and controls to ensure that slavery and human trafficking is not taking place within the Club or its supply chains. 
 
Due Diligence 
 
As part of the Club’s due diligence processes into slavery and human trafficking, the supplier approval process will incorporate a review of the controls undertaken by any given supplier to ensure that slavery and human trafficking is not present within their business or their own supply chain.
 
The Club has also made its staff aware of the Modern Slavery Act, including providing definitions of slavery and human trafficking and also explaining how any suspected breaches of such Act should be reported.
 
High Risk Areas 
 
Imported products, particularly merchandise and training/playing kit, from third parties based outside the UK (and EU) are potentially more at risk of slavery/human trafficking issues.
 
Additionally, by the very nature of professional football, another high risk area is that of “third-party ownership” where the ownership of a player's economic rights is held by third-party sources, such as football agents, sports-management agencies, or other investors.
 
The level of management control required for these high risk areas, along with all others, will be continually monitored by the Club and individually by its suppliers.