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Slavery and Human Trafficking


This statement is made on behalf of APEX Global Sport Group. References to “we”, “us” or “our” in this statement are to APEX Global Sport Group.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit her or him for personal or commercial gain.

We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships. We have implemented proportionate and effective systems and controls to ensure modern slavery is not taking place anywhere in our own business, nor in any of our supply chains.

APEX Global Sport Group is a sport consultancy business, registered in Hong Kong. We provide services to clients around the world.

APEX Global Sport Group is committed to having systems to safeguard against modern slavery existing within our business or supply chain.  We have reviewed our operations and our supply chain to assess the risk of modern slavery taking place, taking into account a number of factors, including the nature of our activities, their location, the sources from which we are supplied goods or personnel and the risk profile of relevant locations.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

A. Operational

APEX Global Sport Group is managed by three founding partners, who meet weekly. We have a long-standing commitment towards ethical, social and environmental responsibility within our business.  We comply with all applicable laws wherever we are consulting for clients. As part of that commitment, we have corporate policies that help us ensure that our business operates in an ethical and responsible way. These include our:

  • Anti-Bribery & Corruption Policy

  • Gifts & Hospitality Policy

  • Conflicts of Interest Policy.

We have robust procedures for recruiting and onboarding casual, temporary, part-time, and full-time personnel.


B. Supply Chain and Supplier Due Diligence

We seek to partner with associates who share our values, and we expect our supply chain to operate fair and equitable practices, whereby modern slavery is not tolerated. We insist that our associates provide services in person and do not sub-contract any aspects of the work.

APEX Global Sport Group has undertaken a risk-based approach to assess the likelihood of the existence of modern slavery within our supply chain.  This risk assessment is an ongoing exercise for our existing supply chain, as well as for potential new suppliers.

C. Compliance with the policy

The prevention, detection and reporting of modern slavery in any part of our business or supply chain is a shared responsibility with all those working for us, on our behalf, or under our control, whatever the nature of that control. Our associates are required to avoid any activity that might lead to, or suggest, a breach of this policy and are advised to notify one of the directors if they believe or suspect that a conflict with this policy has occurred, or may occur in the future.

Where associates or suppliers are unsure as to whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, they are required to raise it with one of the directors immediately.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery - of whatever form - is or may be taking place in any part of our own business or in any of our supply chains.

D. Breaches of this policy

Our zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. We will terminate our relationship with any individuals or organizations working on our behalf if they breach this policy.

APEX Global Sport Group recognizes the importance of maintaining constant vigilance to identify and address any impacts associated with slavery and human trafficking throughout its supply chains, and to continuing to enhance its capacity to identify, prevent and mitigate any actual or potential impacts in this field.

We will continue to assess the effectiveness of the measures we take and we will regularly review and refine our policies and procedures in relation to modern slavery.

Approved by the APEX Global Sport Group Directors: 28 February 2022

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