Modern Slavery Act Transparency Statement
This statement is made in accordance with the requirements of the Modern Slavery Act 2015 (the ‘Act') as they apply to The Gym Group plc, The Gym Limited and all entities in The Gym Group plc group (the ‘Group' or 'The Gym Group'). The full list of entities, and more information on the Group, is in our Annual Report which is available on our website www.tggplc.com.
The Gym Group is committed to compliance with the provisions of the Act. As such, the Group has a zero-tolerance approach to modern slavery and we are further committed to acting ethically, transparently and with integrity in all of our business dealings and relationships.
Organisation structure and supply chains
The Gym Group is a leading provider of low cost, high quality gyms that are open 24/7. The Group has over 1,800 employees and is based in the UK. Our staffing model means that our gyms are managed by our own employees, supported by outsourced providers for services such as maintenance and cleaning.
As such, we consider that the principal areas in which the Group faces risks related to slavery include:
- The Gym Group supply chain;
- Outsourced providers; and
- People working in our gyms and in other functions.
High standards of ethics and business conduct and commitment to operating a sustainable business is important in being a responsible part of the communities in which we operate. The majority of our suppliers are located in the UK, which the Board considers to be lower risk as they are required to comply with the Act and other related legislation.
We describe the risk management and arrangements in place below, including relevant due diligence processes.
Managing risks related to slavery
The Group assesses and manages risk in the above areas as follows:
SUPPLY CHAIN RISK ASSESSMENT AND MANAGEMENT
The Gym Group maintains good relationships with its key suppliers and seeks to treat all suppliers ethically and professionally. As part of our formal risk review process, particularly in light of supply chain and cost of living challenges in the UK, we consider the risk of supplier failure in relation to business interruption and potential reputational risk. In 2022, relationships with key suppliers was escalated to a principal risk for the Company and mitigations outlined in our Annual Report for 2022.
We actively work with our suppliers to understand the significant issues which matter to them and minimise disruption. We consider the supply chain to be an important part of business sustainability, and include suppliers as a key stakeholder as part of our sustainability materiality assessment.
Our annual risk assessment identified emerging risks (risks that, whilst not currently believed to be principal risks to the Group, are clearly important to us and could have a significant impact on the ability of the business to fulfil its strategic objectives in the future) from climate change, which continues to be included in our emerging risks register. We have included a range of scenarios, and mitigating actions within the TCFD disclosures in the Annual Report for 2022.
OUTSOURCED PROVIDERS
Our contracts and relationships with critical suppliers must be well monitored, value for money and regularly reviewed. In addition, third parties must comply with appropriate regulatory and ethical standards and our Supplier Code of Conduct. We operate competitive tender processes for significant contracts, and consider the reputation of suppliers as part of this process. We inform our suppliers that we are not prepared to accept any form of exploitation in their business or any part of their supply chain by publishing our Modern Slavery statement on our website.
In January 2023 we launched our new Procurement Governance Policy with supporting guidance documentation to strengthen our procurement processes and governance. At the same time, we launched our Supplier Code of Conduct, published on our website, which provides clear and concise information on the standards expected from our suppliers, including our expectations around prevention of modern slavery.
We do not currently have formal key performance indicators relating to suppliers.
PEOPLE WORKING IN OUR GYMS AND OTHER FUNCTIONS
As part of our commitment to our employees, we take the following actions:
- We ensure all of our employees have a written contract of employment;
- We ensure employees are legally entitled to work in the UK;
- We provide information to all new employees regarding their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to;
- We communicate with our employees regularly and make available appropriate training and policies relevant to their roles; and
- We ensure our self-employed personal trainers enter into written service agreements and it is verified that they are appropriately qualified and hold appropriate insurance with a reputable insurance firm.
We operate a common employment model for our employees across our sites. Our employment model means that we have over 1,200 part-time Fitness Trainer (FT) employees who work for us for 12 hours per week and outside of these hours run their self-employed Personal Trainer (PT) business in our gyms for which they pay us rent. Our Fitness Trainers have the same employment rights as all other employees and are supported in the same way by our People Team. The advantages of this model and our arrangements ensure we can support our teams by communicating with our FTs effectively.
Policies in relation to slavery and a safe working environment
We have a suite of employee policies intended to support a safe working environment, including whistleblowing, safeguarding and protecting young workers. Some of our policies, such as our Human Rights Policy Statement, can be found on the Sustainability section of our website /sustainability/policy-statements. We are satisfied that we have appropriate working practices and policies in place, and we also review requirements for training or employee guidance in these areas on an ongoing basis.
Training on modern slavery
During 2022, we launched Anti-Bribery, Anti-Corruption and Whistleblowing training module to all staff and refreshed communications around procedures.
We continue to use our communications platform launched in 2020 to ensure policies, guidance and training are clearly and promptly shared with all who need them and proactively engage with our employees. We use a Learning Management System to host, share and mandate workplace learning for all employees, which will support us in ensuring that training and guidance is given to those who require it. The Learning Management System enables us to monitor completion rates across Gym Support and Operations and encourage participation where required.
Board oversight
This statement was approved by the Board of The Gym Group plc on 29 June 2023, and approved for publication by the director named below.
John Treharne
Chair of the Board
The Gym Group plc
Our previous Modern Slavery Act Transparency Statements can be found on our website on /sustainability/reports