It continues to be a priority for Super Group (SGHC) Limited (Super Group) and its wider group of companies and affiliates (the Group) to ensure that we work to prevent modern slavery and human trafficking throughout our organisation and in our Group’s supply chain.
Super Group is the parent company of the Group. The Group operates an online sports betting and multi brand casino gaming offering across a number of regulated online markets and currently holds licences in 24 jurisdictions including (amongst others) the UK, Malta, Italy, Denmark, Spain, Belgium, Germany, Alderney and Ireland. Across the Group there are approximately 4,000 staff with teams in 23 countries.
Operating entities within the Group have various polices in place that operate to protect the public against, amongst other things, problem gambling and that are generally in place for corporate social responsibility. One of the risks these polices address relates to the deterring of modern slavery and human trafficking[.
The Group has a zero-tolerance to modern slavery and human trafficking practices within the Group’s business or along their supply chains. Whilst it is acknowledged that risk factors are present in all global supply chains and across all sectors, it is believed that the Group's relative exposure to slavery, human trafficking and forced labour is low given the nature of the Group’s business as a highly regulated e-gambling enterprise.
The Group operates from offices in Guernsey, Malta, United Kingdom, South Africa and has teams across 23 countries. The Group has an extended network of professional intermediaries (including accountants, lawyers, corporate service providers and e-payment processors). With direct contacts, the Group is able to review practices and test them regularly which is a strong factor in being able to keep the risk exposure low.
The Group is confident that modern slavery or human trafficking practices are not taking place within its own business and is committed to taking necessary steps to ensure modern slavery or human trafficking practices are not taking place within any of the Group’s suppliers and/or affiliates. If an entity within the Group discovered that a supplier or an affiliate was in any way involved in modern slavery or human trafficking practices, it would terminate its arrangement with such entity. Where appropriate, the Group will continue to monitor existing business relationships for their risk management tools in relation to slavery, human trafficking and forced labour and will test relevant new suppliers as to their compliance with any applicable laws and/or regulations.
The Group has a robust recruitment process that ensures appropriate checks on new recruits are carried out prior to the relevant staff member commencing employment. The staff of the Group are protected by its internal policies which are intended to reflect and uphold the Group’s commitment to a high standard of ethics and integrity in its business. Furthermore, all staff employed within the Group are provided with compulsory training on any relevant policies and procedures in order to prevent money laundering, to counter financing of terrorism and to ensure that its online gambling services are not exploited by those wishing to conduct other criminal enterprises. The Group also operates a Whistleblowing Policy which details our procedures for anonymously and confidentially raising any suspected policy or legal breaches (via a third party hotline), and our approach to protecting whistle blowers.
The Group has implemented risk assessment tools locally to assist with the monitoring of its exposure to slavery, human trafficking and forced labour and will keep both the tools and this statement under review as required; including, but not limited to, the use of third-party service providers who can immediately identify if an individual has been convicted of any offence.
Generally, the Group only deals with reputable suppliers of goods and services. It is the Group’s aim to have a fully formalised approach to performing due diligence checks on any new partner or third-party supplier or for renewals of contracts relating to existing suppliers. Where such checks and due diligence process are already in place, these are constantly being reviewed to ensure they are kept up to date with local legislative requirements and that any issues relating to money laundering or other criminal enterprises such as modern slavery and human trafficking are identified.
The Group ensures its contracts with third party suppliers include a requirement for such suppliers to comply with relevant Group policies where applicable This would include any such policy governing the prohibition on modern slavery and human trafficking practices.
The Group aims:
(a) to act promptly where a breach of any slavery, human trafficking or forced labour policy is identified and reported; and (b) to continue to improve its procedures through listening, review and acting appropriately.
This statement is supported by the executive management team, approved by the Board of Directors of Super Group and constitutes Super Group’s slavery and human trafficking statement for 2022.
9th August 2022