London Clubs International Limited trading as “Metropolitan Gaming” takes its responsibility to society seriously. Doing business with integrity remains one of our fundamental corporate values.
Metropolitan Gaming makes the following statement pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for our financial year (to 31 December 2022).
The Group operates casinos and entertainment venues throughout the UK as well as in Egypt.
This statement is made solely on behalf of our UK operations; however, we seek to promote high standards throughout our businesses.
The businesses for whom we make this statement operate in the United Kingdom which, we consider gives Metropolitan Gaming a low exposure to the risks of Modern Slavery.
However, we seek to ensure that companies from which we purchase products and services are operating in an ethical and responsible manner. Our UK supply chain consists of large and small technology suppliers based in the UK and worldwide. In addition, there are the following suppliers based predominantly in the UK;
- Live event suppliers
- Print and logistics suppliers
- Food & drink suppliers
- Outsourced Facilities Management (i.e cleaning services, security, pest control, building maintenance, laundry services)
- Goods suppliers (catering equipment, furniture, marketing collaterals, stationery, uniforms)
- Freelance editorial suppliers
We have re-examined our risk from modern slavery and can confirm that the main risks we have in our supply chain are:
- The use of agency/outsourced labour
- The use of beverages and food products that are sourced abroad by our suppliers
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. This anti-slavery statement reflects our commitment to acting ethically in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place either internally or in our supply chains.
Most of our supply chain we regard as relatively low risk. We regularly review and update our Procurement and Contract Management Policy. We have various due diligence questionnaires which we require suppliers to complete when we perceive that there are particular risks. These risks include but are not limited to modern slavery and human trafficking. For example, those particular risks may be higher in certain jurisdictions and in respect of lesser skilled labour. Direct suppliers in higher risk categories may also to be given our “Supplier Code of Conduct” to which Metropolitan Gaming expects adherence. Where a supplier does not adhere to these requirements our relationship will be reviewed and we may terminate our relationship.
To ensure understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide relevant training to members of staff. This is available on our learning portal. All members of staff undertake a basic training to be aware of Modern Slavery as an issue with additional training for managers who may have to deal with external issues and relationships.
Whilst as a UK based business we consider ourselves a low risk in terms of modern slavery, we recognise that some risk remains. Accordingly, we have a range of HR policies, procedures and guidelines which collectively assist us in ensuring that we can meet the objectives of this statement and provide additional safeguards. Principally, these are:
- Harassment & Bullying Policy
- Grievance Procedure
- Equal Opportunity Policy
- Whistle Blowing (with dedicated hotline number)
We continue to improve our Due Diligence on Suppliers. We review any updated advice from CIPS (Chartered Institute of Procurement and Supply) and HM Government on how to identify and mitigate risks. The Board receives an annual report which will comment on our effectiveness or otherwise in meeting our objectives.
The Board of Directors have considered and approved this statement.
Date 30 January 2023
We are committed to creating a culture of Safer Gambling within our casinos. We have appointed Safer Gambling Ambassadors across all our sites, in order to protect young and vulnerable people from being exploited by gambling, prevent underage gambling and increase support for the treatment of gambling harm.