This Statement explains the steps taken by FC Nairobi Ltd and its associated companies within Typhoon Sports Group Ltd (together, the "Group") to prevent modern slavery in its business and supply chains.
The term "modern slavery" used in this Statement includes slavery, servitude, forced or compulsory labour and human trafficking. References to "we", "us" or "our" are to the Group.
About us
FC Nairobi is a football club based in Nairobi, Kenya. Our activities include football operations, a youth academy, the proposed [Typhoon Sports Village] development, membership, retail, commercial partnerships, events and community programmes.
The majority of our operations are conducted in Kenya through FC Nairobi Ltd, a company incorporated in the Republic of Kenya (company registration no. PVT-XYU8PD8X) with its registered office at Principal Place, School Lane, Westlands, Nairobi, Kenya. "FC Nairobi" is a trademark owned by Typhoon Sports Group Ltd (Company No. 15740405) and used by FC Nairobi Ltd under licence.
Legal framework
We are committed to conducting our business ethically and in accordance with applicable Kenyan law, including the Constitution of Kenya (2010), the Employment Act (2007), the Children Act (2022) and the Counter-Trafficking in Persons Act (2010).
Where applicable, we also have regard to international standards, including the relevant International Labour Organization (ILO) conventions. [If the Group falls within scope, this Statement is also intended to address the requirements of the UK Modern Slavery Act 2015 and/or the US [California Transparency in Supply Chains Act / other applicable US law] — CONFIRM WHICH LAWS APPLY.]
Our approach to modern slavery
The Group has a commitment to ethical, social and environmental responsibility. We comply with all applicable labour laws relating to terms and conditions of work, including pay, and we place great emphasis on equality and diversity.
We maintain a Modern Slavery Policy, overseen by our [Compliance Officer / Safeguarding Lead], which operates alongside our other corporate and people policies, including our Health & Safety Policy, Equal Opportunities Policy, Anti-Corruption Policy, Whistleblowing Policy and Safeguarding Children & Young People Policy.
Our supply chain
We seek to partner with suppliers that share our values and who operate fair and equitable practices in which modern slavery is not tolerated.
We take a risk-based approach to assessing the likelihood of modern slavery in our supply chain, both for existing and potential new suppliers. Where appropriate, we impose contractual requirements, request audit information, and reserve the right to refuse to appoint any supplier whose operations or supply chain fail to meet our requirements.
Reporting
If we, or anyone working for us, becomes aware of any instance of modern slavery within our operations or supply chain, our Modern Slavery Policy provides for reporting to an appropriate manager and/or our [Compliance Officer]. Where a supplier is implicated, we will engage with them and implement an appropriate and timely response, which may include terminating the supply agreement, while prioritising the safety of any victims.
There have been [no / INSERT NUMBER] instances of modern slavery reported in the financial year ended [INSERT DATE].
Training
We provide awareness training to members of staff in functions we consider to be at higher risk, to help them recognise the indicators of modern slavery and understand their role in managing this risk.
Monitoring effectiveness
Our [Compliance Officer] is responsible for monitoring the effectiveness of our Modern Slavery Policy and for ensuring appropriate steps are taken should any issues arise.
Approval
This Statement has been approved on behalf of the Board of Directors of FC Nairobi Ltd.
Signed: [NAME] Title: [TITLE / DIRECTOR] Date: [DATE]
FC Nairobi Ltd — a trademark of Typhoon Sports Group Ltd. This document is provided for general information and does not constitute legal advice.