Modern Slavery Statement

Message from the SIS Group Chairman.

As Chairman of the SIS Group, I am personally committed to ensuring the highest ethical standards and levels of integrity by which all companies and colleagues within the SIS Group carry out our business, wherever they operate throughout the world.

This includes ensuring best practice and transparency throughout the Group and our supply chain partners in relation to the recruitment, employment and treatment of workers throughout our industry. Slavery, servitude, forced labour and human trafficking are unimaginable but very real issues in today’s world economy. It is wholly unacceptable that human beings are denied their freedom and treated as slaves in often appalling conditions.

It is the responsibility of all organizations, commercial and otherwise, to eradicate these illegal activities in the supply chain and I embrace the provisions of the UK Modern Slavery Act but, further, champion the promotion of best practice working conditions and continual improvement of working conditions wherever possible.

Each SIS Group Company shall develop initiatives and strategies to prevent modern slavery and promote good working conditions in its business and supply chain.

SIS employees shall be provided with the right tools and knowledge to identify and avoid the risk of modern slavery and to report any concerns confidentially and without penalty.

I am pleased to endorse the SIS Group Modern Slavery Statement.

George Mullan – Chairman

MODERN SLAVERY TRANSPARENCY STATEMENT - May 2024

We take the aims of the Modern Slavery Act 2015 very seriously and will continue to report on our progress and findings annually in our transparency statement. This is our annual transparency statement for 2024/25 as required under section 54 of the Modern Slavery Act 2015. Our financial year ends on 31 December. This statement has been reviewed and approved by our Chief Executive Officer on May 2024.

Who we are

SIS Pitches design, manufacture, construct, install and maintain world-leading sports pitches for some of the biggest names in sport and as such we are a truly international business, with offices around the world, including UK, Ireland, Turkey, Netherlands, and the Middle East. SIS Head Office and manufacturing plant is in the UK, with operational bases in Maryport – Cumbria, Nottingham. SIS Pitches employs just over four hundred staff across our operations. We provide our customers with a fully integrated turnkey solution using natural, artificial and hybrid grass surfaces, delivering as a FIFA Licensee, a World Rugby Preferred Turf Producer and a certified FIH manufacturer and field builder. Each SIS Pitches division is responsible for its own supply chain. Each divisions product and service mix differ, nevertheless whilst there are differences in our approaches our policies and commitment to addressing Modern Slavery and Human Trafficking is consistent throughout SIS Pitches Group.

Our supply chain consists of around 1,000 suppliers. As a business we are committed to locally procuring solutions within the country of operation, as such, we purchase a range of products and services from across Europe, the Middle East and Asia.

Our Policies

As a certified B Corporation we are committed to operating as an open, honest, and ethical business in accordance with the principals of the Modern Slavery Act 2015. SIS Pitches Group is committed to doing business responsibly, ethically, and sustainably. Our B Corp commitment and the steps being taken to meet it place our ESG performance at the very centre of our purpose. We believe in doing business responsibly, the doing what is right every day and making our purpose and values an engrained part of our culture and practice will drive SIS Pitches towards sustainable growth to our entire value chain, delivering a safer fairer planet for all.

By working together with our supply chain and wider stakeholders, we aim to be the partner of choice for our customers and are committed to operating our business ethically and sustainably. The SIS Pitches Group continues to develop our framework of policies and tools, which help us to tackle Modern Slavery include our Recruitment Policy and Code of Conduct & Business Ethics/Ethical Business Policy. These help to define our standards and expectations.

Our Whistleblowing policy enables staff at all levels on the business to raise concerns relating to trafficking, slavery, servitude or forced or compulsory Labour where may be taking place anywhere in our business or supply chain we encourage staff to let their line manager know and report immediately, either by phone or on-line or to call the local police if the potential victim is believed to be in immediate danger.

OUR RISKS AND MITIGATION MEASURES

AREAS OF RISK
Our internal risks include
Our Supply Chain risks include
Recruitment Temporary LabourLabour
International Subcontractors

Logistics International Contracting

Purchases outside the EU

Suppliers with long, complicated supply chains.

OUR DUE DILIGENCE

Preferred supplier list
Human Rights risk assessment
In place for all permanent and temporary recruitment to ensure that workers have the right to work in the countries we operate, and worker’s own rights are fulfilled such as holiday pay, sick pay and appropriate salary.

A multifunctional working group assembled to assess present and potential human rights impacts within the business and supply chain, putting in place actions where necessary.

Payment processesSupply chain risk assessment
Checks in place on duplicate bank accounts to ensure no suspect activity.We are building our understanding of the risks within our supply chain and taking action to address high risk products or services. Where suppliers are identified as being elevated risk this will be audited and or alternative supplier identifies

Integrity LineSetting Standards
We are committed to an open culture where employees feel secure in seeking advice or raising concerns and have confidence that reports are handled in a professional and transparent way. To help enable this culture, we are establishing an ‘Integrity Line,’ a secure incident reporting contact which employees can report their concerns about any potential breach of our Code of Business Conduct. We set high standards with our UK operations being managed in accordance the ISO9001,45001 and 14001. WFSGI Pledge has been maintained for our UK operation with the intention of carryout social audits at all UK operational businesses and our turf farming activities, prioritising expanding WFSGI over the coming year.

DEVELOPMENT, EDUCATION AND AWARENESS


E-learning training modules
Gangmasters and Labour Abuse Authority’s ‘Construction Protocol’
All managers with recruitment responsibilities have undertaken training.

Intending to become a signatory to the Gangmasters and Labour Abuse Authority’s ‘Construction Protocol,’ committing us to raise awareness within supply chains to help prevent and protect workers from exploitation and take necessary steps to help ensure that exploitation of workers is recognised and addressed with appropriate safeguards.
Awareness campaignAction plans
Encouragement to use of the companies online training resources, bulletin posts, posters, and videos.Where non-compliances are discovered, we collaborate with those suppliers to become compliant by issuing action plans and providing guidance. Where it is appropriate, statutory authorities are always informed.
Labour SupplySupplier day
Agency Labour is now sourced through a single or preferred supplier allowing us to apply stricter governance and maintain consistently high standards across our organisation. We will host ‘People & Communities’ days which focus on education and sharing of best practice for our Modern Slavery, Drug & Alcohol and Fair and Just policies.
Awareness campaign
Refreshing our internal and supplier communication, posters and encouraging open discussion amongst our teams using Toolbox talks and natural conversation.

OUR CONTINUAL IMPROVEMENT

Internal TargetSUPPLY CHAIN ResultTarget
Include awareness of Modern Slavery in all site and business inductionsOn going Site inductions now to include awareness of Modern Slavery issues and how to recognise areas of concernSetting up supplier risk assessment and prioritisation.
Train supervisors and contracts managers.All managers and supervisors across the organisation
have completed training program
2024 TargetsContinue with awareness campaign using posters, internal comms routes, e-learning, and toolbox talks.Continue due diligence and development program using available online training and face to face training, toolbox talks, and supplier engagement
Roll out due diligence, awareness and policies to any new employees or newly appointed sub-contractor.Share modern Slavery messaging and dialog withing supply chain.
Develop Modern Slavery Toolkit for use in our businesses to help increase effectiveness of our response to Modern Slavery challenges, to include commitment state for inclusion on contract packs.Collaborating with selected suppliers to help improve quality and consistency of employment policies and response to Modern Slavery issues.
Carry our social auditing of contracts and staff “way from home” living conditions and facilities.Carry out random sub contractor employee checks.

By implementing our policies and working together with our suppliers we aim to demonstrate that we operate our business ethically, responsibly and sustainably.

Summary

The Board of Directors of SIS Group (Ireland) Limited are pleased to present this statement as the Modern Slavery Statement for the Group, to be reviewed on a regular basis.
The CEO and Chairman commitment is fully endorsed by the Board which will fully support all Group companies in implementing initiatives which will ensure risks around, and vulnerability to, Modern Slavery within its business and its supply chain is identified, controlled within continual improvement in working conditions for all.

This statement was approved by the Board of SIS Group:

Signed: George Mullan – Chairman

Date: 20 May 2024