London Clubs International Limited (“LCI”) (trading as “Metropolitan Gaming”) is the new name of Caesars Entertainment UK Limited.
During 2021 we underwent a change of ownership. As a company we continue to take our 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 2021).
The Group operates casinos and entertainment venues throughout the UK as well as properties in Egypt and South Africa.
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 and have a limited supply chain which, we consider gives MG a lower exposure to the risks of Modern Slavery.
The businesses for whom we make this statement operate in the United Kingdom and have a limited supply chain which we consider gives Metropolitan Gaming a lower 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
Live event suppliers based predominantly in the UK
Print and logistics suppliers based predominantly in the UK
Food & drink suppliers based predominantly in the UK
Outsourced Facilities Management based predominantly in the UK (i.e cleaning services, security, pest control, building maintenance, laundry services)
Goods suppliers based predominantly in the UK (e.g. catering equipment, furniture, marketing collaterals, stationery, staff uniforms)
Freelance editorial suppliers based predominantly in the UK
We have re-examined our risk from Modern Slavery and 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 and with integrity 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.
We will not tolerate slavery and human trafficking. Most of our supply chain we regard as relatively low risk. During 2021, we updated our Procurement and Contract Management Policy which requires us to consider where the risks may be greater and to prioritise those risks. For example, risks may be higher in certain jurisdictions and in respect of lesser skilled labour. In such riskier circumstances, we will require a Risk Assessment Questionnaire to help us better understand the risks. Direct suppliers in higher risk categories will 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 training to relevant members of staff where required
We have launched a training video on Modern Slavery for relevant team members to review on our learning portal. Key members of our HR and Procurement Teams are expected to undertake this training.
We consider ourselves a low risk in terms of Modern Slavery. However, we have a range of HR policies and procedures which collectively assist us in ensuring that we can meet the objectives of this statement and provide additional safeguards. Principally, these are:
We discuss with other Casino operators as well as hospitality companies to discuss our approach and share best practice. We will 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.
We will endeavour to get further insight into our supply chain through prequalification and understanding our suppliers’ supply chains. The Board of Directors have considered and approved this statement.
Date 19th January 2022
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.