Modern Slavery Statement 2026

Gibson O'Neill Company Limited Modern Slavery Statement

ABOUT US

This statement has been prepared and published by The Gibson O’Neill Company Limited for and on behalf of itself and its group companies (“the Group”) including Bulkhaul Ltd, Rockliffe Hall Limited, The Pheasant Hotel (Harome) Limited The Feversham Arms Limited and Middlesbrough Football & Athletic Company (1986) Limited in accordance with the Modern Slavery Act 2015. It sets out the approach by the Group during the year ending 30 June 2025 to prevent modern slavery and human trafficking in its business and supply chains.

Our Group companies span the sports, hotel & leisure and international haulage industries and we have a diverse range of supplier and commercial partners who operate in different industries and territories throughout the world. The risk of modern slavery can vary across our company locations, industries and operations and we manage these risks according.

As a group we are committed to fair employment, equality and diversity and supply chain practices in line with our core values and behaviours and all relevant labour legislation.

 

WHAT IS MODERN SLAVERY?

Modern slavery is a crime and a violation of fundamental human rights. Modern slavery can take many forms including slavery, servitude, forced or compulsory labour and human trafficking. The underlying principle is the exploitation of a person or the coercion of a person to work against their will for the benefit of another.

 

OUR APPROACH TO MODERN SLAVERY

As a Group we recognise the importance in maintaining a vigilance to identify and address issues associated with modern slavery of any kind in our supply chains.  We remain committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure the same high standards from our contractors, suppliers and other business partners.

We continue to take a pragmatic approach to promote a zero tolerance of modern slavery in any form in our business or supply chains and prevent worker vulnerability by:

• working with key staff to raise awareness and communicate the importance of due diligence checks and placing responsibility on all departments to take appropriate steps to identify and mitigate modern slavery risks within the commercial lifecycle
• conducting due diligence on our potential suppliers via a Supplier On-Boarding Process
• working closely with suppliers and sub-contractors and potential suppliers and sub-contractors to ensure they understand the importance of modern slavery due diligence in the supply process. We have established standards of conduct for our business-related practices contained within the Code of Conduct for Suppliers & Representatives which reflects our commitment to our values of humility, respect and honesty & integrity and inclusion. The Group expects all suppliers to share, embrace and demonstrate these values together with commitment to legal and regulatory compliance. The Group expects its Suppliers and Representatives to share its commitment to human rights and equal opportunity and inclusion in the workplace. In addition to the obligations under the Supplier’s agreement and Code of Conduct for Suppliers & Representatives with the respective Group company, all Suppliers and Representatives are required to follow our ethical standards, which include expected conduct in the areas of regulatory compliance, business practices and employment including obligations on suppliers and sub-contractors to comply with the Modern Slavery Act in our contractual agreements and terms of business and refusing to work with third parties who cannot commit to meeting the standard we expect
• training staff on Modern Slavery and Trafficking to promote awareness and understanding to assist in recognising and identifying potential risks
• having robust safeguarding policies and procedures and training in place to protect children and adults at risk in line with relevant governing body rules and guidance (where applicable) managed by the Safeguarding Team. Designated Safeguard Officers are accessible for individuals and staff to raise any safeguarding concerns they have which are then reported directly to the Head of Safeguarding.  A formal reporting procedure is in place.  The Safeguarding Team work closely with the HR Department and the Legal Department and in partnership with statutory agencies, local authorities and sporting and charity governing bodies.  Middlesbrough Football Club has a safeguarding reporting platform that facilitates a discreet and confidential way for individuals to disclose concerns directly to the Club should they feel unable to do so face to face
• having a clear framework of rules and behaviours that encourage the reporting of any concerns or breaches of such, or any law or regulation via our Grievance Procedure or Whistleblowing Procedure so that such can be dealt with appropriately in accordance with our policies and procedures
• having robust recruitment procedures in place supported and communicated by the Recruitment and Selection Policy and conducting eligibility to work in the UK checks before any appointment commences within any Group company. We have processes in place to ensure that all staff are paid no less than the National Minimum Wage which involves monitoring hours worked by salaried staff to ensure their hours are not excessive resulting in their hourly rate falling below National Minimum Wage. In addition, we use a preferred suppliers list to source temporary workers
• conducting annual reviews, updates and communication of our Equal Opportunities Policy, Whistle Blowing Policy, Bullying & Harassment Policy and Equality and Diversity Statement of Commitment
• committing to ongoing training promoting the eradication of discrimination within the Group and also within the region by using our elevated profile and status within the local community via Middlesbrough Football Club Foundation initiatives supported and promoted by Middlesbrough Football Club including the “Active Through Football inclusion football sessions

 

• proactively promoting equal opportunities by treating people fairly and with respect; by recognising inequalities exist; by taking steps to address them; and by providing access and opportunities for all
• continuing to consult and engage with key staff, best placed to advise on our supply chains, to conduct risk assessments to identify areas within our businesses most at risk, and to develop policies and procedures that are practical and effective in eliminating identified risks
• engaging with local authorities and other stakeholders to maintain open communication about issues affecting the local community and working together to address any concerns

 

MONITORING EFFECTIVENESS

We continue as a Group to assess the effectiveness of our approach to Modern Slavery and to ensure ongoing improvement.

 

This statement is made pursuant to section 54 Modern Slavery Act 2015 and sets out the steps taken by the Group to prevent Modern Slavery and human trafficking in our businesses and supply chains.

This statement was approved by the Board of Directors of The Gibson O’Neill Company Limited on 02 January 2026.

 

Mike O'Neill

Managing Director

The Gibson O'Neill Company Limited.