This statement set out the steps taken to prevent modern slavery and human trafficking in our business in accordance with the Modern Slavery Act 2015.

our structure

Freedom Leisure is one of the largest not for profit community leisure operators managing over 95 facilities in England and Wales, mainly in partnership with local authorities. Our head office is based in East Hoathly, East Sussex and we were formed in 2002. Our annual turnover is in excess of £70m and we employ over 5,000 staff. We do not have any trading activity outside of the United Kingdom. We are an HMRC exempt charity for tax purposes and a Registered Society under the Co-operative and Community Benefit Societies Act 2014.

our business

Our key objective is to provide affordable and accessible leisure and sport activities for everyone in the community and to improve lives through leisure. We aim to have a positive impact on people’s lives by inspiring people to be more active, more often in whatever way we can. Our main activity is the supply of services to the public, rather than the supply of goods. 

our supply chain

Our supply chain mainly consists of the provision of goods to us from other organisations, all of which are based in the United Kingdom. These goods are required by us to deliver our services to our customers. The main areas of supply to us relate to repairs and maintenance, equipment, cleaning, utilities and catering. As part of our review for this statement we have identified that there are some items being sourced from our suppliers from outside the United Kingdom, such as uniform and maintenance parts.

Our procurement from these suppliers is a centralised function which requires the use of pre approved suppliers which means we have controls in place for committed expenditure and also the option to complete due diligence and retrospective checks.

Our procurement policy is designed to ensure we operate in a legal and ethical manner. We expect all suppliers to commit to comply with all laws, regulations and our policies and terms of supply. We take a zero tolerance approach to abuse of human rights, slavery, servitude, forced or compulsory labour and human trafficking. Any supplier that fails to meet our standards will jeopardise their ability to trade with us and we may ultimately cease trading with any such supplier.


We work closely with the community in all of our centres and we have noted that the most vulnerable groups in the UK for modern slavery could include migrant workers, illegal immigrants, asylum seekers, homeless people, travellers and people suffering from learning difficulties. We have detailed procedures, operating documents and training for safeguarding which educates our staff on Modern slavery for the workplace and to help identify anyone in the community we believe may be at risk.

our staff

Freedom Leisure has strict HR policies and procedures that ensure compliance with legislation and ensures fair and equal treatment, dignity at work and prevents discrimination.  Our policies and operating documents are available to all staff on our intranet. We encourage all staff to report any activity they believe to be in breach of any of our operating standards or policies to us.

due diligence

We are committed to ensuring there is no modern slavery or human trafficking in any part of our business. We will:

  • Identify and assess risks in our supply chain and ensure compliance from our suppliers.
  • Provide training for our staff in these risks.
  • Protect whistle blowers.

David Talbut Signature




David Talbut - Freedom Leisure Finance Director | January 2021