Modern Slavery Statement

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 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 2024 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 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 potential suppliers 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, humility, respect and honesty. 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 in the workplace. In addition to the obligations under the Supplier’s

agreement with the Group, all Suppliers and Representatives are required toThe Gibson O’ Neill Company Limited Modern Slavery Statement 2024

follow our ethical standards, which include expected conduct in the areas of

regulatory compliance, business practices, and employment

• including obligations on suppliers to comply with the Modern Slavery Act in our

contractual agreements and terms of business and refusing to work with suppliers

who cannot commit to meeting the standards we expect

• training staff on Modern Slavery and Trafficking to promote understanding and

awareness to assist in recognising and identify potential risks

• having robust Safeguarding Policies and Procedures and training in place to

protect children and vulnerable adults 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 Legal Department and in partnership with statutory

agencies, local authorities and the football, golf and charity governing bodies.

Middlesbrough Football has a safeguarding reporting platform that facilitates a

trusted way to disclose concerns by individuals directly to the Club should they

feel unable to do so face to face. It is a discreet and confidential way to voice

concerns in respect of issues such as bullying, abuse or mental health

• having a clear framework of rules and behaviours and encourage the reporting of

any concerns or breaches via our Whistleblowing Procedure so that they 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 the Group. 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 “Club

Together Refugee Programme”

• 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

MONITORING EFFECTIVENESS

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

ongoing improvement.The Gibson O’ Neill Company Limited Modern Slavery Statement 2024

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 01

July 2024.

Mike O'Neill

Managing Director

The Gibson O'Neill Company Limited.