Modern Slavery Statement

Introduction

Modern slavery is the illegal exploitation of people for personal or commercial gain. Victims are controlled by force, threat, coercion, and deception. It can take various forms including trafficking of people, forced labour, sexual or criminal exploitation, or domestic servitude.

At Showsec, we are firmly committed to identifying, preventing, and addressing modern slavery risks within our business operations and supply chains, including our third-party labour providers. We expect the same commitment from all our stakeholders, including suppliers and clients.

Our commitment to transparency, ethical conduct, and compliance with the Modern Slavery Act 2015 is central to our operations. This statement outlines our approach, actions, and future objectives in combatting modern slavery. It is available to all staff and on Showsec’s company website.

The statement has been divided into the following categories:
• Structure, business, and supply chains
• Policies
• Risk assessment, prevention, & mitigation
• Training and awareness
• Effectiveness
• Looking forward

1. Structure, Business & Supply Chains

Our purpose is to manage crowds to a level of excellence across different operating environments and give audiences positive experiences. To do this we offer specially trained staff who are managed by our effective management structure including regional managers, area managers, and client focused operations managers located across the UK. In addition to this, we have 450 supervisors and over 3,500 stewarding and SIA-licenced security staff.

Head office departments including HR, finance, recruitment, training, IT, and booking support our operations.

Showsec has a structured third-party supply chain. Each company is required to evidence that they have completed the necessary checks to prevent modern slavery, illegal working, sexual harassment at work, breaches of health and safety legislation, as well as compliance with employment law. This evidence is saved in their compliance folders, which are managed by the resource planning team.

We regularly collaborate with our industry partners to share best practices and tackle wider issues. Currently, we’re members of the United Kingdom Crowd Management Association (UKCMA) which presents key commercial organisations whose primary business is providing crowd management and event security services. Showsec is also a member of the City Security Council.

Showsec holds the following accreditations:

• the SIA-approved contract scheme (ACS) status for the provision of security guarding, and
door supervision.
• certified with ISO 9001, the internationally recognised standard for quality management in
businesses.
• Recognised by the international institute of risk and safety management (IIRSM)
• Accredited CHAS contractor with a recognised standard of health and safety management and covers compliance regarding our field of work.

Responsibility for our modern slavery policy and program sits with our board of directors, Mark Logan (co-CEO), Simon Battersby (co-CEO), and Stephen Shilling (Finance Director).

2. Policies

We have several policies that help us manage our modern slavery risk. They enable all staff, and our suppliers to have a joined-up approach in tackling the threat of modern slavery. In addition, as part of Live Nation Entertainment, their training, and policies on modern slavery, business ethics, and whistleblowing apply and are cascaded to Showsec personnel where this is deemed applicable.

Staff can access our policies on SharePoint or via the SmartG8 app for casual workers. Our key
policies for preventing and reporting modern slavery are:

Modern slavery and human trafficking
The policy supports all staff to understand what modern slavery is, our commitments as a
responsible employer, our expectations of any third parties we work with, and how to report
concerns.

Corporate social responsibility
The policy sets out the standard of behaviour expected of staff, contractors, and suppliers. It has a section dedicated to Human Rights and includes information about our commitment to act responsibly. This policy is linked with the company values which are to act with integrity, take responsibility, and find solutions.

Commercial policies
The procurement policy integrates modern slavery prevention requirements, defining clear
protocols for risk assessment (including risk management matrix), audits, and supplier onboarding.

Whistleblowing policy
The whistleblowing policy is managed in line with Live Nation Entertainment’s global strategy on whistleblowing. It confirms that anyone can raise concerns about wrongdoing taking place within Showsec (including at an event venue). Various channels are available for people to raise concerns including a 24/7 reporting service that allows reports to be made anonymously.

3. Risk assessment, prevention, and mitigation

Showsec remains focussed on reducing the potential for modern slavery and risk is assessed and managed utilising the procurement Risk Management Matrix (RMM). The RMM aims to identify the completion of minimum requirements to provide labour support, products or services to Showsec.

The RMM criteria varies dependent on whether the procurement is related to labour provision or products and services.

The minimum requirements for suppliers of products and services are as follows:

VAT Status
• The supplier must be VAT Registered

Public Liability Insurance
• The provider must hold Public Liability Insurance of £5 million or more

Employers Liability Insurance
• The provider must hold Employers Liability Insurance of £5 million or more
For procurement over an annual value of £2,500 the following must also be provided:

Modern Slavery Policy
• The provider must be able to provide a Modern Slavery Policy or Statement

Credit Check
• An Experian credit check must be conducted on the provider
For procurement over an annual value of £10,000 the following must also be provided:

H&S Policy
• The provider must be able to provide a Health & Safety Policy or Statement

Equal Opportunity Policy
• The provider must be able to provide an Equal Opportunity Policy or Statement Local
Authority, HSE, HMRC, Home Office or Immigration Enforcement Notices
• The provider must disclose details of any local authority, HMRC, Home Office or Immigration enforcement notices.

Statutory Accounts
• The provider must supply a copy of their latest Statutory Accounts as filed at Companies
House. If the accounts are more than one year old, they are required to send a declaration of
their profit and loss account and balance sheet up to the latest year end.

For procurement over an annual value of £50,000 the following must also be provided:

Quality Standards Certificates
• The provider must supply copies of any quality standard certificates such as ISO 9001,
Safecontractor or Safesupplier accreditation etc.

Sustainability and Environmental Policies
• The provider must be able to provide copies of their Sustainability or Environmental Policies
or Statements

The minimum requirements for suppliers of labour are as follows:

• Legal Status – they must be registered with Companies House as a limited company.
• VAT Status – they must be VAT registered.
• Insurances – they must have indemnity, public liability, and employers’ liability insurance over £5 million (per policy)
• SIA – they must be approved contractors under the SIA Approved Contractor Scheme.
• PAYE Compliance – they must pay their staff through PAYE.
• H&S – they must have an up-to-date Health & Safety policy.
• Recruitment Screening – they must screen their staff to BS7858.
• Cost competitiveness (value for money) – they must accept the pay rate we offer.
• Service level coverage – they must evidence their ability to provide staff to the area/region in which we require support.
• Ability to meet requirements – they must evidence that they have enough working staff to service our requirements.
• Company profile and stability (including ethics) – they must comply with all disclosure obligations under the Modern Slavery Act 2015.
• Communication and technology – they must be able to evidence their ability to adhere to our policies and procedures. Including their ability to utilise the contractor booking portal.

The RMM considers the strategic, compliance/regulatory, operational, financial and reputational risk of the supplier.

All purchase orders over £500 need to have a purchase order raised for them through Showsec’s internal database, SmartG8.

Suppliers who are not successful in their screening will be provided with the reasons for this. If they can rectify this then a new RMM can be completed for them, however, no agreements will be made from any supplier, for any purpose, if a successful RMM has not been completed.

Auditing of documentation is completed at either 6 monthly, 12 monthly, or 24 monthly depending on the supply of services. Auditing may be undertaken more frequently should there be an issue with poor performance, increased risk, reports of compliance breaches, or as part of a randomised sample audit.

Showsec regularly reviews and updates its risk management procedures to align with evolving best practices, ensuring that our supply chain remains resilient against modern slavery risks.

4. Training and Awareness

Showsec manages an internal training program for all staff on the learning platform, Coursebeam. The ‘LNE Code of Business Conduct and Ethics’ is a requirement for all full-time staff to complete during their induction. This training links to the policies already mentioned in this statement.

Operations-based managers are trained through the Management Development Programme (MDP) scheme.

Training and awareness with industry partners remain a focus for Showsec and the industry to stamp out slavery and human trafficking.

All staff working for Showsec are required to complete recruitment screening according to BS7858 standards. Third-party labour providers are required to screen to the same level.

5. Effectiveness

To measure the effectiveness of our modern slavery program, Showsec tracks and reviews key
performance indicators (KPIs), including:

• Training completion rate: Currently, 100% of our required staff have completed the LNE Code
of Business Conduct and Ethics training.
• Audit compliance scores: We monitor audit results for our labour providers and suppliers,
taking corrective actions as needed.
• Incident and grievance monitoring: We categorise and review complaints or reported
grievances related to modern slavery or unethical conduct. No modern slavery incidents have
been identified within Showsec’s operations to date.

These metrics are reviewed quarterly by the Head of Risk and Operational Compliance, who reports to the Board of Directors to ensure continuous improvement and accountability.

6. Looking forward
We look forward to making further business improvements over the next financial year. We aim to continue working closely with our suppliers, regulators, and our industry working groups to improve our internal processes and controls as well as our external facing schemes.

We remain committed to continuously improving what we do in this area to reduce the risk of
modern slavery.

Signed:

Mark Logan Co-CEO

Date:04/11/2024