Modern Slavery and Human Trafficking Statement
Creative Artists Agency UK Limited
1 This statement is prepared for the purposes of Part 6 (Section 54) of the Modern Slavery Act 2015 on behalf of Creative Artists Agency UK Limited and all UK group companies including but not limited to CAA Sports UK Limited, CAA ICON UK Limited, CAA Brands UK Limited, ICM Stellar Sports Limited and Base Sport Limited (the “Group” or “we”) and forms our slavery and human trafficking statement for the financial year ending 30 September 2023. The statement sets out the steps the Group has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.
2 The Group is part of global talent agency Creative Artists Agency (CAA). CAA is the leading entertainment and sports agency, with global expertise in filmed and live entertainment, digital media, publishing, sponsorship sales and endorsements, media finance, consumer investing, fashion, trademark licensing, and philanthropy. CAA represents more than 3,000 of the world’s top athletes in football, baseball, basketball, hockey, soccer, in addition to coaches, on-air broadcasters, and sports personalities and works in the areas of broadcast rights, corporate marketing initiatives, social impact, and sports properties for sales and sponsorship opportunities. Founded in 1975, CAA is headquartered in Los Angeles, and has offices in New York, Nashville, Memphis, Chicago, Miami, London, Munich, Geneva, Stockholm, Shanghai and Beijing, among other locations globally.
3 We aim at all times to carry out our business in compliance with local laws and best practice. The CAA Code of Ethics and Business Conduct (the “Code”) applies to all CAA personnel worldwide and we expect all employees to conduct themselves ethically and in compliance with the law. Where relevant and as set out in paragraph 6 below, we also require third parties with whom we do business to act in a way that is consistent with the Code. The Code provides information, resources and tools to help guide our employees’ actions including in relation to respect for human rights and combating abuses of them, whether through human trafficking, slavery, child labour or otherwise. The Code also details CAA’s policies and procedures relating to grievances, ethics, fraud and corruption, disciplinary issues and whistleblowing which allow and encourage any employee, consultant, contractor, supplier or agency worker with relevant information about modern slavery or human trafficking to come forward without fear of retaliation and also to allow the Group to take any necessary corrective action immediately. No concerns about modern slavery or human trafficking have, to the knowledge of the Directors of the Group, been raised at any time in the year under review.
4 As a professional services organisation, our primary activity is brokering revenue generating agreements between our clients and third parties. Our clients are generally professional athletes or creative artists who enter into such agreements as principal and are responsible for obtaining their own independent tax and legal advice. As such, we consider the risk of modern slavery within our primary business activities to be low.
5 The professional football (soccer) transfer system can involve the movement of minors across international borders. Any such movement is subject to strict regulation by FIFA and by national football associations. Where we are involved in such movement, this is carried out in accordance with relevant laws and regulations (including, where applicable, relevant screening and checking requirements).
Our supply chain
6 Our "supply chain" in relation to the provision of professional services to our clients consists in the main of other services delivered to us. There are very limited circumstances where we may provide our services via a third party supplier, for example providing on-ground hospitality services at an event we have organized as part of our provision of services to a client. Where relevant for the services being provided, we contractually require third party suppliers to comply with our Supplier Code of Conduct, available online at https://www.caa.com/legal/supplier-code-conduct (and see paragraph 12 below). This states that CAA has a zero-tolerance policy for the use of child or forced labour or human trafficking practices. We also require suppliers to comply with all applicable laws, of which laws prohibiting modern slavery would be a part. Some suppliers may have their own direct obligations under the Modern Slavery Act and/or their own regulatory oversight regime in any event. We have not received any report of the existence of exploitative practices (slavery, child labour or trafficking) in any of those businesses. Consequently, we believe these providers to present a low risk so far as issues with trafficking and modern slavery are concerned, and so we do not at this stage take or propose to take any specific action in relation to these services relationships beyond our normal supplier contractual and approval processes. If our experience or perception of the extent of that risk changes then this position will be revisited.
7 We do not generally supply goods to our clients or to third parties except as ancillary to the provision of the professional services referenced in paragraph 6 above (e.g., a limited range of branded items as part of a client event). Where relevant for the goods being provided and if practicable in all of the circumstances, we will contractually require third party suppliers to comply with our Supplier Code of Conduct. Consequently, we believe these providers to present a low risk so far as issues with trafficking and modern slavery are concerned, and so we do not at this stage take or propose to take any specific action in relation to these services relationships beyond our normal supplier contractual and approval processes. If our experience or perception of the extent of that risk changes then this position will be revisited.
8 To the very limited extent to which we are supplied with goods ourselves, many will be ordinary office consumables and promotional items and obtained in the main from substantial, established and reputable office suppliers, whether in the UK or overseas. Those suppliers may have their own obligations under the UK Modern Slavery Act (or overseas equivalent in relation to their supply chain).
9 We also receive services in relation to our own operations through the use of external contractors to provide our cleaning, catering, maintenance, mail room, photocopying, security, transport, hotel/travel booking and reception services.
10 We consider that the supply of internal (non-professional) services and of goods may (being for the most part not professionally regulated and/or sourced from countries with less well developed legal protections against exploitation) as set out in paragraphs 8 and 9 above carry a marginally greater risk of slavery or human trafficking than the “supply chain” services referred to in paragraph 6 above. However, we do not consider there to be a material risk of slavery, child labour or trafficking in any business relationship concerning the supply of goods or services to us over which we have any direct control. We have however developed certain minimum conditions to be included where practicable in our arrangements with approved suppliers of such goods and services. To be "approved", we generally require a prospective supplier to provide certain information and undertakings about its supply chain and other business practices. The nature and extent of the information requested from each supplier is proportionate to the perceived risk, having regard to factors including the volume, frequency and value of goods and/or services to be supplied, any unusual time or costs pressures to be imposed by us, the nature of the goods or services and their geographical origin, the supplier's market reputation and the history of our prior dealings with it, if any.
11 We use this information to assess the extent of any risk of slavery, child labour or human trafficking in that supplier's (and hence our own) supply chain. As matters stand as at the date of this statement, these processes have not given us any reason to suspect the existence of child labour, modern slavery or human trafficking issues in this part of our supply chain. Compliance with these terms and the absence of any grounds for suspicion on our part of such issues are pre-conditions for any supplier's tender being taken forward through our procurement processes.
12 As referenced in paragraphs 6 and 7 above, we require compliance with our Supplier Code of Conduct with all relevant suppliers. The Supplier Code of Conduct sets out the standards we expect our suppliers to uphold at all times relating to various matters including anti-bribery and corruption, labour and human rights, safety and ethical behaviour. We are currently reviewing our internal processes to ensure that the issuance of our Supplier Code of Conduct to suppliers is embedded into our procurement process across all of our various business lines.
13 Although we are confident that the issue has never so far arisen in practice, we are aware of the need to avoid imposing demands on our suppliers which, by reason of their size or urgency or pricing or timing of payment of their bills may force or encourage those suppliers to resort to slavery or trafficked labour to meet them.
14 Responsibility for the Group’s compliance with the Modern Slavery Act lies on an operational basis with the Office of the Chief Legal Officer (OCLO) and its HR and Facilities teams, and managerially with the senior management of the Group. This statement is issued with the consent of the senior management of the Group.
Jeffrey M. Freedman
Director of Creative Artists Agency UK Limited
4 May 2023