Modern Slavery Act Transparency Statement 2020
Flutter Entertainment plc is headquartered in Dublin and employs more than 14,000 people globally. Flutter operates some of the world’s most recognisable sports betting, gaming, and entertainment brands, including Paddy Power, Betfair, FanDuel, Sportsbet, Poker Stars, and Sky Betting and Gaming. Our mission is to deliver a vibrant and safe sports betting and gaming experience to our customers around the world.
We recognise that modern slavery is a global threat that imposes an intolerable burden on those affected by it and that every step must be taken to reduce the suffering it causes. More than 40 million people worldwide are estimated to live in slavery or are trafficked daily, though the total number may be even higher. It is complex in nature and the signs of it are not always easy to detect. It is incumbent on all organisations to ensure that their operations remain free from this invidious practice.
As a global operator, Flutter is committed to preventing slavery and human trafficking in all areas of our business and we expect the same commitment from our employees, contractors, suppliers, and business partners. In 2020, we focused efforts on further developing our policies on modern slavery, and on extending the tools we employ to more effectively screen our suppliers for risk or exposure to instances of forced labour and human trafficking.
Across our operations, Flutter has a high proportion of colleagues performing highly-skilled roles. The majority of our employees are based at offices in Ireland, UK, Isle of Man, Malta, Australia, USA, Romania, Portugal, Italy, India, Bulgaria and Georgia. The remainder of our colleagues are based in our retail shops in the UK, Ireland, and the US.
In 2020 Flutter merged with The Stars Group, significantly increasing the size and scale of the organization and its supply chain. Working towards universal group policies in that context requires time and planning, nonetheless work is significantly underway in relation to establishing common policies and approaches and the nature of the supply chain has not altered significantly in terms of supplier profile.
Flutter’s supply chain is large, encompassing close to 10,000 suppliers globally. Most of our supply chain spend is in skilled sectors such as professional services, marketing, and information technology. The most common countries of origin for our suppliers include the UK, USA, Ireland, and Australia.
Policies in relation to slavery and human trafficking
Flutter recognises that modern slavery in all its forms is a complex problem with no single root cause. We therefore have a range of policies in place that combine to ensure our employees and suppliers are aware that we have a zero-tolerance approach to the issue.
This year, Flutter expanded the reach of our supplier code of conduct to include operations in the US and Australia and we are working towards adopting it in all locations globally in 2021. This code outlines our ethos and principles and sets out the standards of behaviour we expect from our suppliers. The updated code contains specific requirements in relation to modern slavery and will be communicated to all new and existing suppliers as its scope is extended.
To further mitigate against the risk of modern slavery across our supply chain, we endeavor to ensure that all contracts with suppliers require them to comply with all applicable laws and regulations. Furthermore, our procurement policy requires that, in assessing the suitability of a supplier or partner partnership, staff are directed to have specific regard to any risk of modern slavery within or posed by the new supplier.
We have robust employee processes in place and conduct background and verification checks on all employees and contractors to mitigate the risk of slavery and trafficking. Our employee Code of Conduct encourages employees and contractors to identify and report any suspicions of modern slavery taking place. We also have a whistleblowing policy to ensure that employees and contractors can voice any concerns that they may have without fear of suffering any detrimental treatment. These measures are further supported by our Anti-Bribery and Corruption Policy, which has been refreshed in 2020 with a view to rolling out a Group policy in 2021.
In 2020 we updated our Code of Ethics on a groupwide basis and will be communicating it to all employees in 2021. This code contains specific provision in relation to identifying and reporting any risk or suspected incidence of modern slavery within the Group’s operations.
Due diligence processes in relation to slavery and human trafficking
Flutter’s operations are primarily in developed markets that generally present a low risk of modern slavery and the vast majority of our suppliers are in high-skilled sectors that are also rated low-risk. Also of note is that Flutter’s primary operations are typically in countries whose governments have been the most responsive to the threat of slavery. As such, initial risk assessments placed the group in the low-risk category.
Nonetheless, Flutter understands the importance of remaining vigilant in relation to this issue. 2019 saw us invest heavily in a new monitoring and reporting tool. The aim of this initiative is to allow Flutter to more effectively screen new and existing suppliers against a range of harmful activities, including the risk of modern slavery within their operations. The use of the tool is being extended to include monitoring of those suppliers on a groupwide basis commensurate with their risk profile. The screening is not just performed on entities but can be extended to directors and beneficial owners.
If a supplier is found to exhibit a risk of such practices in its operations, our procurement process requires immediate further investigation to take place with the outcome that the relationship be immediately terminated should any presence of slavery in the supplier’s operations be confirmed.
From an employer perspective, we conduct background checks on all employees and contractors to mitigate the risk of slavery and trafficking. All new hires are subject to verification checks, including national ID/passport checks, education checks, and right to work documentation.
Risk of slavery and human trafficking within business and supply chain
Flutter operates an entertainment business that is predominantly online based, with some retail presence and live events in countries, generally at low-risk of modern slavery. Additionally, most of our procurement spend is also in skilled sectors with a similarly low-risk profile. We also abide by all relevant domestic employment legislation in the countries where our staff are employed.
Nonetheless there may be certain areas of the supply chain that display a higher risk profile. In any organisation of Flutter’s size and scale, some suppliers may have issues deeper within their own supply chain. Flutter will continue to monitor our suppliers for non-compliance with our commitment to preventing modern slavery and we will be particularly vigilant in relation to suppliers in higher-risk countries and sectors.
Effectiveness in ensuring slavery and trafficking is not taking place
To date, tens of thousands of entities and individuals in Flutter’s supply chain have been screened for risks associated with modern slavery. None of the screenings have revealed any confirmed instances of modern slavery in relation to the screened parties. Additionally, there have been no calls to Flutter’s confidential reporting mechanism outlined above. Flutter is committed to continuing to screen for such practices. The absence of any negative outcomes to date reinforces our belief that the group’s operations are at low-risk of such activities.
We remain determined to expand and deepen the screening to account for the global nature of our supply chain and will continue to be proactive in monitoring our business for breaches.
All procurement staff are trained in the updated codes of conduct and all relevant staff in the operation of the risk monitoring tool. Additionally, all HR staff are appropriately trained in the relevant procedures applicable to the risk of modern slavery in the recruitment process.
Any material legal, operational or reputational issues can be reported via an international, independent, whistleblowing service. HR processes are in place to manage any risk in the recruitment process and escalate accordingly.
Our future commitments
- To review and update our modern slavery statement every year in line with our commitment to ensuring that our business and supply chain remain free from any association with breaches of the Act;
- To continue to develop our policies and processes to ensure our approach remains commensurate with our risk profile; and
- To monitor changes in our business and in the environments in which we operate to capture and manage any new or evolving risks so that our zero tolerance approach to modern slavery is maintained.
Approved and signed on behalf of the Board of Flutter Entertainment plc
Group Chief Executive Officer