Modern slavery statement

A message from our Founder & Chairman

Modern slavery has no place in our businesses, or in the businesses we work with. As 247 Group has grown, so has the number of people our success depends on: our own teams, and the suppliers, contractors and partners behind our brands, properties and venues. We take our responsibility to all of them seriously.

This is our first statement under section 54 of the UK Modern Slavery Act 2015. It sets out how the group is structured, where we see the greatest risk, and the steps we are taking, now and over the next twelve months, to prevent slavery and human trafficking in our operations and supply chains.

Our structure and business

247 Group of Companies is a private holding company with its head office in Dubai, United Arab Emirates. It owns and invests in businesses in the United Kingdom and the United States, with teams based in the North East of England, Dubai and the US. This statement covers 247 Group and the businesses it controls, which include:

• a full-service digital agency providing marketing, paid media, web, software and video services to our own businesses and to external clients
• e-commerce brands selling consumer products online, each run day to day by its own brand operator
• a portfolio of residential and commercial property in the UK
• hospitality businesses, including bars and takeaways
• fulfilment operations: our own warehouse in the UK, our own fulfilment hub in Texas, and space in a shared fulfilment centre in the Netherlands
• a small number of early-stage ventures in Dubai

Group functions, including finance, acquisitions, brand leadership, legal and compliance, people and operations, are shared across these businesses.

Where we hold a minority stake in a business, such as our investments in padel clubs and boxing gyms, that business is run independently by its own management and isn’t covered by this statement. We use our influence as an investor to encourage the same standards we set for ourselves.

Our supply chains

Our main supply chains are:

• consumer products and packaging for our e-commerce brands, bought from third-party manufacturers and suppliers
• logistics and delivery services, including couriers and freight
• construction, fit-out, maintenance and cleaning services for our properties and venues
• food, drink and supplies for our hospitality businesses
• security services, provided by a specialist contractor
• professional, technology and outsourced services, including software, freelance and creator services for our agency, and customer service, compliance and finance support for some of our businesses
• office and building services for our Dubai office

Our commitments

Across the group, we commit to:

• check every person’s right to work before they start
• never charge anyone a fee to get a job with us, directly or through an agency
• never hold anyone’s passport or identity documents, or restrict their freedom to leave their job
• pay everyone at least the legal minimum wage wherever one applies, in full and on time
• give everyone written terms of employment in a language they understand
• make it safe for anyone to raise a concern, in confidence and without fear of retaliation

We expect our suppliers, contractors and recruitment agencies to meet the same standards. During the year ahead we will set these out in a Supplier Code of Conduct and share it with our suppliers, starting with those in higher-risk areas.

Due diligence

Our approach is proportionate to our size, and focuses on the areas where the risk is greatest.

• Suppliers. We prefer to work with established suppliers and contractors we know. Our property team, for example, uses a small pool of trusted tradespeople for maintenance. New suppliers in higher-risk areas will be asked to confirm that they meet our standards before we work with them.
• Contracts. We will add modern slavery terms to contracts with suppliers in higher-risk areas as they are agreed or renewed.
• Agencies. If we use recruitment or staffing agencies, for example to bring in extra staff at busy times, we will check that they are properly established and that their workers are paid fairly and directly.
• Acquisitions. We are adding modern slavery and labour practices to the due diligence we carry out before buying a business.

Assessing the risk

In preparing this statement, we reviewed our businesses and supply chains to identify where the risk of modern slavery is greatest. We consider these to be our higher-risk areas:

We consider the risk within our own central teams to be lower, because these are mostly skilled roles that we recruit for directly.

How we reduce the risk

• introducing our Supplier Code of Conduct, starting with suppliers in higher-risk areas
• adding modern slavery terms to new and renewed contracts in higher-risk areas
• checking the right to work of everyone who joins our businesses, before they start
• giving anyone a clear, confidential way to raise a concern, set out below
• training the people who hire staff and choose suppliers

Training

Over the next twelve months, managers who recruit staff or choose suppliers will complete training on recognising the signs of modern slavery and what to do if they suspect it. Our Legal & Compliance team will support them.

Measuring our progress

We will measure our progress over the next twelve months against these indicators, and report on them in our next statement:

Raising a concern

Anyone, inside or outside the group, can raise a concern about modern slavery or human trafficking connected with our businesses by emailing office@the247.group with “Modern slavery” in the subject line. Concerns are handled in confidence by our Legal & Compliance team, and we won’t tolerate retaliation against anyone who raises a concern in good faith.

If you think someone is in immediate danger, call the police on 999. In the UK, you can also call the Modern Slavery & Exploitation Helpline, free and in confidence, on 08000 121 700.

Approval

This statement is made under section 54(1) of the Modern Slavery Act 2015. It has been approved by the board of 247 Group of Companies, and we will review and update it every year.