SLAVERY AND HUMAN TRAFFICKING
STATEMENT FOR FINANCIAL YEAR 2018
(Adopted July 1, 2018)
This statement sets out the steps that we, McCullough Group, LLC, have taken across our Company to ensure that slavery or human trafficking is not taking place in any part of our own business or supply chains. This statement relates to actions and activities during the financial year 2019, 1 July 2018 to 30 June 2019.
STATEMENT FROM THE CHIEF EXECUTIVE OFFICER
McCullough Group, LLC recognizes the importance of combating slavery and human trafficking, a crime that affects people and communities globally. We endorse a purposeful mantra to improve the lives of others, as well as a passionate commitment to opportunity for all. As such, we are totally opposed to such abuses of a person’s freedoms both in our direct operations, our indirect operations and our supply chains.
We are proud of the business standards our Company endorses, as set out in the MGLLC Standards of Business Conduct. We are proud of the steps we have taken, and are committed to build upon, to ensure that slavery and human trafficking have no place either in our own business or our supply chains.
Managing Partner & CEO
MEANING OF SLAVERY AND HUMAN TRAFFICKING
For the purposes of this statement, slavery and human trafficking is based on the definitions set out in the Modern Slavery Act 2015 (the Act). We recognize that slavery and human trafficking can occur in many forms, such as forced labor, child labor, domestic servitude, sex trafficking and workplace abuse and it can include the restriction of a person’s freedom of movement whether that be physical, non-physical or, for example, by the withholding of a worker’s identity papers.
McCullough Group, LLC (together with its subsidiaries, MGLLC, the Group, the Company, we or us) is a private equity company comprised of businesses across a range of diversified consumer services, including, but not limited to: personal development, baking, peak performance training, as well as group fitness services.
RESPONSIBILITY FOR COMPLIANCE WITH OUR STATED VALUES AND STANDARDS
The Universal Compliance team, assisted by Corporate Audit and local legal, compliance, human resources, finance and procurement teams, will, going forward from the date of this statement, co-ordinate and be responsible for all necessary activities to monitor the relevant MGLLC companies’ compliance with the values and standards as set out in this statement.
We will periodically review the effectiveness of the steps we are taking to ensure there is no slavery or human trafficking in our supply chains. Our aim is to continually monitor and, where necessary, improve any policies, procedures and systems that we have already implemented.
This statement is made pursuant to section 54(1) of the Act and constitutes the slavery and human trafficking statement for the financial year ending 2018 for McCullough Group, LLC inclusive of the relevant subsidiaries of MGLLC to which the Act applies.
The board of directors of the Company and each of the relevant subsidiaries of MGLLC have, at properly convened board meetings, viewed a copy of this statement, approved it and delegated authority to sign it on their behalf to the CEO of the Group.