Introduction from the CEO
The Stars Group Inc (‘TSG’ or the ‘Company) and its subsidiary companies (individually or collectively, the ‘Group’ ; ‘we’ ; ‘our’), promotes a zero-tolerance approach to enforced slavery, servitude, forced or compulsory labour and human trafficking (‘Modern Slavery’) in all its guises within the Group’s direct operations and its supply chain. We recognise our corporate responsibility to be alert to the risks in our business and in our relationships with suppliers, and have made our staff aware of the Group’s commitment on the topic via policies, procedures and training.
This anti-slavery and human trafficking statement (‘Statement’) is made pursuant to Section 54 Part 6 of the Modern Slavery Act 2015 (The Act) and has been adopted by each of the Group companies as our joint and unified Group statement on Modern Slavery. This Statement identifies the business, people and systems and controls identified as key to the prevention of Modern Slavery taking place in our business or in any of our supply chains.
The Act creates offences in respect of slavery, servitude, forced or compulsory labour and human trafficking. We are committed to combatting all such forms of Modern Slavery and carrying out our business in a fair, honest, ethical and open manner.
The Group’s Board remains cognisant of the continued risks, impacts and costs of global Modern Slavery and fully supports both the original principles of the Act and the UK government’s guidance regarding the Act and Modern Slavery. We maintain a zero tolerance approach to Modern Slavery in all its forms, in any part of our business and supply chain and we continue to apply the UN guiding Principles on Business and Human Rights and core labour standards set out by the International Labour Organisation.
We have an ongoing process, supported by contractual terms with our suppliers, to ensure that, to the best of the Group’s ability, there is no form of Modern Slavery in our own business and operations or within our supply chains.
TSG is a Canadian gaming and online gambling company traded on the NASDAQ stock market and the Toronto Stock Exchange. We employ over 4,000 staff globally and are headquarted in Toronto, Ontario, Canada. TSG is the ultimate owner of industry leading gaming brands which attract more than 100 million registered customers, making TSG one of the largest online gaming businesses in the world. A significant part of TSG’s operational services is delivered from the United Kingdom (via the Sky Betting and Gaming Brand) TSG has accepted and adopted, as good practice, compliance with the Act across the whole Group.
TSG is an international online gaming company Group, with licences or applicable approvals to operate in multiple jurisdictions, including in Europe, both within and outside the European Union, North America, Australia and elsewhere. Our scalable technology platform, passionate personnel, regulatory experience, reputation and global exposure allows us the Group to focus on developing and acquiring interactive, technology based assets with high growth potential in existing and new markets and industries.
Our Supply Chain
Given the nature of the Group’s business, we consider that the risk of Modern Slavery being present in our supply chain is low. However, we continually assess these risks across the Group and especially as we enter and consider new markets. Furthermore, we continue to insert clauses dealing with Modern Slavery requirements and expectations into all of our relevant supplier contracts. TSG has a robust supplier due diligence programme in place that assists with the identification of high risk suppliers/ services.
We will not knowingly support or do business with company/suppliers involved in Modern Slavery.
In addition to our Anti-Slavery and Human Trafficking Policy, our employees are subject to and benefit from a wide range of policies and training, which cover equality and diversity, anti-bribery and corruption, and our Anti Money Laundering learning and development programme identifies Modern Slavery as a significant and growing source of criminal wealth. The existing policies and frameworks that we have in place help the Group to minimise the risk of Modern Slavery being present in our workplace and encourages all staff to be alert to Modern Slavery in TSG’s supply chain.
We also operate a whistleblowing policy for employees to raise any concerns that they may have and for those concerns to be investigated.
TSG’s Corporate Integrity Department is responsible for ensuring our ongoing compliance with the obligations and the application of the principles enshrined within the Modern Slavery Act.
TSG is committed to and will;
- Continually assess the exposure to Modern Slavery across the Company’s supply chain
- Enforce the Company’s zero tolerance approach to Modern Slavery
- Continue to build long standing relationships with our suppliers and make clear our expectations regarding conduct in this specific area
- Continue to communicate to our employees and suppliers through clear policies and procedures – which will be available on our intranet and website; and
- Take appropriate action wherever behaviours or activities not consistent with Company policies are reported and / or discovered.
TSG will conduct an annual review of this Statement. This Statement is made in accordance with section 54(1) of the Act for the financial year ending 31 December 2019.
This statement has been formally approved by the Compliance Committee, and is endorsed by Rafi Ashkenazi, Chief Executive Officer.
The Sky Betting and Gaming Group, as a subsidiary of TSG fully complies with the Statement.