Compliance

Modern Slavery Act

beIN MEDIA GROUP WLL (“beIN”) is a multi-national media company with operations in Pay-TV, Sport, Original Programming, Movies and General Entertainment with a presence in over 43 countries across 5 continents and in 9 different languages spanning Europe, North America, Asia, Australasia and the Middle East & North Africa (“MENA”). We recognise that our activities, and those of third parties that form our supply chain, provide opportunities to positively impact our employees’ working and living environments and set a standard as a responsible global employer.

This statement is made in accordance with section 54 of the Modern Slavery Act 2015 (the “Act”) on behalf of beIN IP Limited, beIN Europe Limited and beIN IH Limited (the “Companies”). Our statement identifies the steps we have undertaken (in our most recent financial year) to identify and address the risk of modern slavery that may potentially result from our supply chains.

About us

beIN IP Ltd is the central rights acquisition entity for the network of the beIN Sports channels worldwide. The company provides commercial, strategic and legal support in relation to the acquisition of sports media rights on behalf of the beIN MEDIA GROUP and its subsidiaries.

beIN IH Ltd is the international holding company of beIN Europe Ltd and beIN IP Ltd as well as other subsidiaries in regions such as APAC and the US.

Our responsibility and commitment

beIN is against all forms of modern slavery and we are committed to ensuring that modern slavery practices are not taking place in our business operations or our supply chains. We understand that modern slavery is a fundamental breach of human rights and that it can take many forms, such as debt bondage, forced labour, human trafficking, bonded labour, etc. We believe that all businesses have a responsibility to identify and eliminate modern slavery in all its forms.

As one of the world’s leading sports and entertainment media companies, we recognise that while our direct operations have a low risk of modern slavery, there may be some risk inherent in our supply chains, depending on the sector of the services we require, the labour source employed, the operating context of the supplier and the contract type employed. We are committed to identifying, remediating and preventing modern slavery in our supply chain.

We recognise that we cannot meet this commitment alone. Preventing modern slavery is a collective responsibility and any meaningful impact requires a continual dialogue with our suppliers and business partners. We have a responsibility to understand and identify modern slavery risks in our business and we will work with suppliers, experts, partners, civil society, and government entities to prevent them. We will seek to assist our suppliers and partners in adhering to our commitments and compliance standards and will cease our partnerships with entities that fail to meet those standards, if necessary.

This statement has been approved by the Board of Directors of beIN MEDIA GROUP on 31 March 2020.

How we address Modern Slavery

We are at the start of our journey to identify and prevent modern slavery risks in our business and supply chain. Since March 2019, we have made progress in understanding our exposure and in developing a foundation of the structures, policies and compliance standards, we need to implement to meet our commitments. As we look forward to 2020 and beyond, we have set our teams an ambitious implementation plan and will continue to work closely with our stakeholders to understand the risks we face.

Our progress this year

In our first group modern slavery statement for 2018/19, we recognised the need to scrutinise our supply chain to understand where there is a risk of modern slavery. We also identified that there was an opportunity to conduct risk-based due-diligence during our procurement activity. During 2019, we began work to identify the risks of modern slavery in our operations and supply chain. This year we:

  • Conducted a pilot risk assessment of our tier one 1 supply chain and used this to develop a supply chain risk assessment model that we intend to use to assess and monitor our global supply chain going forward.
  • Are introducing a labour rights policy and compliance requirements, setting out our commitment to the fair and equal treatment of all workers in our operations and supply chain.
  • Developed a supply chain risk assessment model for our procurement department to assess the risk of modern slavery during the procurement phase able to determine the risks posed by the supplier of any future tenders and contract renewals.

Risk assessment

Our understanding of the risks of modern slavery in our supply chain is evolving. We started a pilot risk assessment to map our tier one suppliers within the group with a focus on MENA and Turkey. 2 Our mapping was conducted using a supply chain risk assessment model designed to provide an indicative assessment of the risk of modern slavery based on the country-level risk factors and the labour-type risk factors used in the supply of the goods or services by third parties. During this initial, internal assessment, we identified that our operations in MENA were likely more exposed to certain modern slavery related risks within their supply chains due to:

The operating context:

There may be a presence of low-cost, migrant labour, variances in worker representation and maturity of third party suppliers’ compliance with local labour laws and legislation.

The nature of work:

Some of the third party supplier contracts supporting our operations in MENA may rely on certain labour skills who, when considered with the operating context, are likely to be exposed to coercive recruitment practices.

To validate the desktop analysis of our tier one suppliers in MENA and Turkey, we also consulted with a wide variety of internal stakeholders in our business who procure goods or services from those suppliers. We used these discussions to educate internal stakeholders on the indicators and root causes of modern slavery and to identify parts of our business where they believed modern slavery risk exposure may exist.

The stakeholders helped to identify specific contracts and services where there could be at-risk workers, and some examples were collected of potential poor working practices within our third party supply chain. This information has been used to direct further enquiry and to develop remediation and control strategies (see below).

Looking ahead

In 2020, we intend to expand our supply chain risk assessment to other markets of operation, namely Europe, North America and Asia Pacific, to ensure that all our tier one suppliers have been mapped to ensure that we are consistent in our global compliance standards and supplier risk assessment practices.

Our pilot “indicative risk” model

To direct our further due diligence on the contracts and suppliers that could be at-risk of modern slavery, we used data sources on the country and labour basis where the goods or services would be sourced from and delivered. We used two primary external data sources; a country-level labour market risk rating provided by a global specialist risk consultancy Control Risks’ CORE platform and open-source data from the Global Slavery Index 2018 (“GSI”). Our indicative risk model (supply chain risk assessment model) combines data from both sources to determine an initial risk rating for each contractor to guide further due diligence practices.

Labour rights policy

In the year ahead, we will introduce a labour rights policy and compliance requirements, setting out our commitment to the fair and equal treatment of all workers in our operations and supply chains. The policy is based on best practices from the United Nations Guiding Principles on Business and Human Rights, the International Labour Organisation Fundamental Conventions, and recognised international frameworks including the Dhaka Principles for Migration with Dignity.

Looking ahead

In 2020, starting with our MENA and Turkey pilot, we aim to roll out our policy to all our global tier one suppliers. We will require that our commitments are understood and implemented by all employees, suppliers and business partners, who are contractually required to adhere to and apply them in their own supply chain. The labour rights policy and commitments will be managed by a dedicated group compliance team and will be updated as necessary on a yearly basis to remain in line with international best practices.

We recognise that a policy alone does not prevent modern slavery abuses so, to ensure that our suppliers ‘walk the walk’, this financial year we will request tier one suppliers to provide evidence of their understanding and compliance, and to make measurable improvements where they fall short.

Due diligence and monitoring

To support the compliance with our labour rights policy, we have developed a due diligence process for our procurement department during contract tender and renewal, that builds on our indicative risk model and requires our internal end-users to provide relevant and up to date information about the suppliers; and where required followed by an assessment of documentation to show compliance with our labour rights policy and related supplier compliance requirements, checklist and guidance.

The development of the indicative risk model, labour rights policy and the supplier compliance checklist and guidance will enable us to implement a robust supplier due diligence program for new suppliers.

Our due diligence process (Procurement)

All new suppliers will first be rated by our procurement team using our indicative risk model (supply chain risk assessment model). They will work with end-users within the business to confirm the country where the services are performed, and the labour type used to deliver the service required. Where a supplier is assessed as medium or high risk, we will require the supplier to submit evidence of compliance with our labour rights policy. In addition, where a supplier is still found to be a high-risk following the submission of evidence, further dialogue will be held with the supplier to manage the risk or disqualify their tender. Where the supplier is accepted, monitoring will be triggered to address the root causes of the issues identified.

Looking ahead

By the end of 2020, we intend to refine and update the supplier compliance checklist and guidance based on feedback from the suppliers, internal end-users and the assessment findings, as necessary. The supplier compliance checklist and guidance will be an evolving document that seeks to provide the best advice to our suppliers as we strengthen our understanding of modern slavery risks and labour rights abuses.

Monitoring

Looking ahead

Going forward, we plan to introduce monitoring for those suppliers who we have identified as being at-risk of having modern slavery issues within their business. Our monitoring criteria are based on our own labour rights policy which details high level principles and specific compliance requirements, which incorporate key applicable elements from the International Finance Corporation Performance Standards 2 on Labour and Working Conditions 3, and the Global Reporting Initiative Social Standards 4.

In 2020, we will identify high-risk suppliers, using tools developed for our due diligence process, and conduct monitoring activities. The monitoring activities will primarily target suppliers operating in MENA and Turkey but will also include suppliers from other regions who are assessed as high-risk. The monitoring activities conducted will vary depending on the type of services or products provided by the supplier, but may include visits to the suppliers’ corporate offices to review documentation indicative of their employment practices, direct interviews with suppliers’ employees, inspections of employer-provided accommodation to assess living conditions or inspections of production facilities to assess the working conditions. Each monitoring activity will be conducted in line with our labour rights policy’s principles and compliance requirements and will aim to identify not only the issues of concern but to assist the supplier in remedying the issues through the provision of suggested actions.

Education

We have an opportunity to have a positive impact in our supply chain through educating our suppliers and working with them to improve their employment practices. To support the implementation of our labour rights policy we have developed guidance for suppliers and by the end of 2020 we intend to have communicated our policy and compliance expectations throughout our global tier one supply chain.

Looking ahead

In 2020, we will issue internal communications to our employees to announce the development of our labour rights policy, principles and compliance requirements for suppliers. We will also involve the internal end-users in the initial assessment of suppliers and require that they are actively seeking assurance of the suppliers ability to comply with our labour rights policy. The findings of our assessment and our subsequent risk rating assigned to our existing and new suppliers will be analysed and sailent issues of concern will be extracted and reported on to relevant internal stakeholders

Grievance reporting and remedy

We understand that the success of tackling modern slavery risks in our supply chain will depend on communicating our labour rights policy throughtout our supply chain and in enabling concerns within our operations to be reported to us. It is important to use that those affected, as well as those witnessing violations, can raise complaints freely and get effective resolutions at all stages of employment, including the recruitment process

Looking ahead

We recognise that our grievance reporting is not yet fully developed, and within the next year we will investigate and select the most suitable options to meet our above aims. Central to this will be a solution that encourages working with our suppliers to ensure that any issue reported is fully investigated and assurances given that workers are not penalised as a result. Currently, there are ad-hoc remedies available to address any issues identified.

 

1 A tier supplier is a third party that provides good and services to beIN directly

2 The initial pilot risk assement could be focused on tierwhose contract values exceed USD 250,000

3 https://www.ifc.org

4 https://www.globalreporting.org

 

Global Tax Strategy

Introduction

beIN MEDIA GROUP and its subsidiaries (collectively the “Group”) are a global sports and entertainment media group that carry out TV production, media rights acquisitions and their distribution. The Group broadcasts 60 channels across 5 continents within 43 countries and in 9 different languages.

Governance and Risk Management

beIN MEDIA GROUP is committed to paying the right amount of tax within the timelines set by relevant laws/regulations, in all the jurisdictions in which it operates. beIN MEDIA GROUP seeks to structure its affairs based on sound commercial principles and in accordance with relevant tax legislation.

The importance of commercial needs should in no circumstances override compliance with applicable tax laws. As a matter of practice appropriate external professional and specialist advice is sought. This is particularly so, where there may be areas of uncertainty.

beIN MEDIA GROUP identifies, evaluates and mitigates tax risks. As part of its governance beIN MEDIA GROUP has established the following in relation to taxation:

 

Key Functions Description
Tax Function profile

The Tax function falls under the Finance function headed by an Executive Director of the Group. The tax function is led by the Group Head of Tax who is a UK qualified tax professional with the responsibility for management of the Group’s tax affairs.

The Group Head of Tax, together with his team, manages and oversees the Group’s tax compliance. This includes and not limited to providing support on tax matters across the Group.

The Tax Function is also supported by external tax advisors where appropriate.

Training & Development

beIN Medial Group recognizes the evolving nature of taxation and strongly embraces professional development.

The Group Head of Tax ensures that they are up to date through regular professional and industry training. In addition, they are charged with responsibility for providing relevant updates and training to wider business functions, as appropriate.

Protective Partnering

We aim to ensure that the business understands the Group Tax Function’s objective of minimizing tax risk and exposure. We have established communication protocols with different business functions and provide education/information as appropriate to ensure that they consider tax and engage with the Group Head of Tax when undertaking transactions and/or making business decisions ensuring tax input is obtained on a timely basis.

Tax Controls

Tax matters are proactively managed by the Group’s robust internal business controls and processes. In this regard, the tax function provides appropriate input as part of the approval process for business transactions/proposals to ensure a clear understanding of the tax consequences is established at the outset.

Tax planning

Tax decisions are made in a manner that is consistent with beIN MEDIA GROUP’s business strategy and operations. Appropriate professional advice is sought from external professional firms. Transactions undertaken are driven by the business and commercial needs of the operating business. The advice sought from reputable firms enables us to evaluate both non-tax and tax implications and associated risks.

In its approach to the level of risk in relation to taxation, beIN MEDIA GROUP is not prepared to accept a level of risk that would expose the business to reputational harm.

Relationship with tax authorities

beIN MEDIA GROUP is committed to the principles of openness and transparency in its approach to dealing with the tax authorities wherever we operate around the world. All dealings with the tax authorities and other relevant bodies are conducted in a collaborative, professional, courteous and timely manner.

This document is published in compliance with Paragraph 19(2), Schedule 19, Finance Act 2016 which requires beIN MEDIA GROUP to set out the tax strategy of its UK companies. This global tax strategy covers the entire Group, including the UK entities 1 , and applies for financial year end 31 December 2019

1Specifically, from UK perspective covering the UK sub-group of beIN IH Limited and its UK subsidiaries.

 

Corporate Criminal Offence

Anti-Facilitation of Tax Evasion – Corporate Criminal Offence (“CCO”) Policy

 

Introduction

The CCO was introduced in the UK Criminal Finances Act 2017 and became effective as of 30 September 2017. A business is criminally liable if it fails to prevent those who act for it, or on its behalf (“Associated Persons”) such as employees, agents or service providers, from criminally facilitating tax evasion in the UK or overseas. beIN MEDIA GROUP LLC and its subsidiaries (“beIN”) therefore have a legal responsibility to ensure that those acting for, and on its behalf, do not facilitate tax evasion. Any breach may result in unlimited fines and other sanctions for beIN, as well as significant reputational damage.

beIN is committed to preventing the facilitation of tax evasion by individuals or businesses within its operations. The following policy (the “Policy”) outlines the expectations regarding tax evasion and its facilitation of those who work for or on behalf of beIN.

What is the facilitation of tax evasion?

Tax evasion means deliberately and fraudulently underpaying or not paying tax and “criminal facilitation of tax evasion” refers to deliberate and dishonest action (or omission) to assist another person to evade tax in the UK or abroad.

Tax means all forms of taxation, whether owed in the UK or abroad, including corporation tax, incometax, withholding tax, value added tax, stamp duty and national insurance contributions.

Who must comply with this Policy?

This Policy applies to all persons working for beIN, or on its behalf, including employees, volunteers, interns, casual workers, agency staff, contractors, distributors and other third partiesincluding agents, freight forwarders, advisors and service providers.

All members of staff and all who have, or seek to have, a business relationship with beIN must familiarise themselves with this Policy and are required to act at all times in a way which is consistent with the Policy.

Policy

The purpose of this Policy is to:

  • set out beIN’s responsibilities, and the responsibilities of those working for or on behalf of beIN, in preventing the criminal facilitation of tax evasion; and
  • Provide information and guidance to those working for or on behalf of beIN on how to recognise and avoid tax evasion.

Business should be conducted at all times in a manner such that the opportunity for, and incidence of, tax evasion is prevented. beIN is committed to the following principles:

  • to not sell goods or provide services where it is suspected that any aspect of the transaction may be being misused by a customer for the purposes of tax evasion;
  • to not buy goods or services from any supplier where it is suspected that any aspect of the transaction may be improperly declared in order to evade tax;
  • to terminate any agreement or trading relationship as soon as beIN learns that tax evasion is or may be taking place;
  • any employee found to be in breach of the Policy will face disciplinary action; and
  • no employee will suffer demotion or other adverse consequence for refusing to engage in the sale or purchase of goods or services or any other business where they suspect tax evasion to be taking place.

Employees, agents and all people acting for or on behalf of beIN must not:

  • cause beIN to commit a tax evasion offence;
  • facilitate a tax evasion offence by a third party;
  • fail to promptly report any request or demand from any third party to facilitate the fraudulent evasion of tax by any person, in accordance with this Policy; or
  • engage in any other activity that might lead to a breach of this Policy or the applicable CCO rules.

Any employee, agent or person acting for or on behalf of beIN who participates in any such activities will also be subject to strict disciplinary action, including termination of employment or the assignment in compliance with applicable laws.

Potential Risk Scenarios

The following is a non-exhaustive illustrative list of possible red flags that may raise concerns related to tax evasion:

  • you become aware that a third party has made or intends to make a false statement relating to tax (e.g. failing to disclose income or gains to a relevant tax authority);
  • you become aware that a third party has deliberately failed to register/account for VAT;
  • a third party requests payment in cash and/or refuses to sign a formal agreement, or to provide an invoice or a receipt for a payment made;
  • a third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;
  • a third party service provider asks for the services rendered to be described on an invoice in a way that seems designed to obscure the nature of the services;
  • there is a lack of a clear business purpose for the proposed activities or transactions of a third party;
  • you observe documents which appear to be false or altered, refer to fictious events or persons, are backdated, deliberately misleading or otherwise suspicious; or
  • a third party subcontractor obtains results which are suspicious due to being substantially more favourable than seems reasonable, suggesting that bribes or undeclared payments may have been made.

Implementation and Review

This Policy will be published on beIN’s website and reviewed annually by the Board of Directors.

Training and Communication

All beIN Directors are aware of the UK’s CCO rules. A CCO video-based training module is distributed to all UK staff and those whose actions may come under the scope of the legislation.

Reference to this Policy is included in applicable agreements with suppliers, contractors and others who intend to have a business relationship with beIN, and these parties must read, agree and adhere to it (and by extension, agree to beIN’s zero-tolerance approach to tax evasion).

beIN’s Associated Persons are encouraged to raise concerns about any issue or suspicion of tax evasion as soon as possible. Any known or suspected events should be reported immediately to the local Finance Director copying the Group CFO and the Group Head of Tax.

 

Labour Rights Policy

belN Labour Rights Policy

belN Media Group WLL (“belN”) is a multi-national media company with operations in Pay-TV, Sport, Original Programming, Movies and General Entertainment with a presence in over 43 countries across 5 continents and in 9 different languages spanning Europe, North America, Asia, Australasia and the Middle East & North Africa (“MENA”). We recognise that our activities, and those of third parties that form our supply chain, provide opportunities to positively impact our employees’ working and living environments and set a standard as a responsible global employer.

Our responsibility

belN has a responsibility in building the world of tomorrow, where a common respect and understanding of differences in cultural diversity and background is encouraged and promoted. To this end, we have incorporated our corporate values of sportsmanship, fair play, honour, dignity and mutual solidarity and coupled them with the principles at the heart of our identity – accountability, integrity and respect to develop this labour rights policy.

Our policy and commitments

We are committed to upholding the employment rights of all those who work for belN, whether employed directly by us or indirectly by our third parties. This policy defines our commitments to the well-being, safety, security and dignity of employees and is based on best practices from the United Nations Guiding Principles on Business and Human Rights 1, the International Labour Organisation Fundamental Conventions 2 and recognised international frameworks, including the Dhaka Principles for Migration with Dignity 3

 

belN Compliance Requirements

Our commitments are supported by the following compliance requirements.

We are commited to
1. Fair and equal treatment for all 5. Safe and decent working and living conditions
2. A workforce free of child or forced labour 6. Providing access to grievance mechanisms
3. The freedom to exercise legal rights 7. Fair and free recruitment
4. The right to freedom of movement 8. Wages being paid in full, directly and on time

 

Applying our commitments

We recognize that due to beIN’s international footprint, these commitments may differ from legal requirements in some of our countries of operation and in such instances the applicable governing law shall prevail. beIN’s labour rights policy and commitments are however an integral part of our corporate values and we will seek to implement them to the fullest. Our labour rights policy and the compliance requirements derived from each commitment are applicable to ell beIN employees as well as the employees of our third parties.

How we will meet them

We require that our commitments are understood and implemented by all employees, suppliers and business partners, who are contractually required to adhere to our commitments and apply them in their own supply chain.

We continually monitor our own operations and assess third-party suppliers at the procurement stage to ensure conformance with the commitments and make imrpvoements and will take necessary actions where required.

Our monitoring criteria are based on our principle and compilance requirements, which incorporate key applicable elements from the international Finance Corporation Performance Standards 2 on Labour and Working Conditions4 and the Global Reporting Initiative Social Standards.5

This labour rights policy and commitments are managed by a dedicated group compliance team and will be updated as necessary on a yearly basis to remain in line with international best practices.

 

1. Fair and equal treatment for all
1.1 Discrimination Employees are not subject to discriminatory practices during recruitment or employment.
1.2 Harassment Employees are not subject to any form of harassment.
1.3 Equal opportunity Employees receive equal opportunity, pay and treatment.
2. A workforce free of child or forced labour
2.1 Child labour No employees below the legally permitted minimum age are employed.
2.2 Harassment All work must be voluntary, and no forced or indentured labour is used.
3. The freedom to exercise legal rights
3.1 Guarantee of legal rights Employees are free to exercise all their legal rights, with no retribution from the employer for doing so.
3.2 Freedom of association Employees shall have the freedom to establish and join organisations of their own choosing whilst maintaining the contractual obligations of employment and in accordance with the applicable law in that jurisdiction.
3.3 Right to organisation Employees shall enjoy adequate protection against acts of anti-union discrimination in respect of their employment, where relevant. Should national legislation prohibit this, employers shall make reasonable effort to assist with alternative means for employees to create committees to further their interests and in accordance with the applicable law in that jurisdiction.
4. The right to freedom of movement
4.1 Personal document retention Employees’ identity documents or other valuable items, including passports and bank cards are not confiscated.
5. Safe and decent working and living conditions
5.1 Health, Safety and Environment Employees are provided with safe, secure and healthy working environments.
5.2 Living conditions Employer-provided housing and food are compliant, hygienic, safe and healthy (as applicable).
5.3 Transportation Employer-provided transportation to and from work sites is safe and roadworthy.
5.3 Transportation Employer-provided transportation to and from work sites is safe and roadworthy.
5.4 Insurance Employees who are not covered by applicable public national health services shall receive employer-funded medical insurance for the duration of their employment and workers’ compensation (work accident) benefits in accordance with the applicable law in that jurisdiction.
5.5 Working hours Working hours are compliant with local regulations and do not jeopardise the health of employees.
5.6 Leave Employees receive paid annual, sick and maternity leave in accordance with the applicable law in that jurisdiction.
6. Providing access to grievance mechanisms
6.1 Grievance mechanism Employees have access to a clear and concise grievance reporting mechanism, which provides multiple avenues of reporting.
6.2 Disciplinary procedures Any disciplinary measures are clearly communicated, consistent and in line with applicable laws.
7. Fair and free recruitment
7.1 No fee recruitment The costs of recruitment and visa processing are borne by employers.
7.2 Contract transparency Wages and benefits are clearly communicated during recruitment and match employment contracts.
8. Wages being paid in full, directly and on time
8.1 Fair wage Employees’ wages are compatible with the national minimum wage where applicable or are sufficient to ensure minimum acceptable living standards where no minimum wage is set.
8.2 Wage payment Employees receive their full monthly wages and overtime dues as per the applicable law, through electronic bank transfer within 15 days of the completlon of the month.

 

1https://www.ohchr.org

2https://www.ilo.org

3http://www.ihrb.org

4http://www.ifc.org

5http://www.globalreporting.org