Modern Slavery Statement

This statement is made by Pathway, owned and operated by Kronos Consulting Group LTD ("Pathway"), and sets out the steps we take to ensure that slavery, human trafficking, forced labour, and child exploitation are not taking place anywhere in our business or supply chain.

1. Our Position

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms — slavery, servitude, forced and compulsory labour, and human trafficking — all of which deprive a person of their liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business relationships.

2. Our Business

Pathway is a global football organisation operating across Latin America, Africa, Asia, and Europe. Our work involves club ownership, partnerships, player development, and community investment. Because our model brings young athletes and coaches across borders, we hold ourselves to a particularly high standard on safeguarding and ethical recruitment.

3. Risk Assessment

We continually assess the risk of modern slavery within our network, with specific attention to:

• Recruitment of young athletes and the protection of minors.
• Cross-border player movement and visa / immigration compliance.
• Working conditions at partner clubs and academies.
• Supplier and contractor due diligence in each region.

4. Policies

Our policies reflect our commitment to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our network. These include our Safeguarding Policy, Anti-Slavery Policy, and Code of Conduct.

5. Due Diligence

Before entering into any partnership or ownership arrangement, we conduct due diligence on the entity, its leadership, and its recruitment practices. We require partners to commit, contractually, to standards no lower than our own.

6. Training

Staff and senior leaders receive training on modern slavery risks relevant to their role and region of operation. Specific safeguarding training is mandatory for any role with contact with young athletes.

7. Reporting Concerns

Anyone with concerns regarding modern slavery within Pathway or our network is encouraged to report them confidentially to info@kronosconsulting.com. We do not tolerate retaliation against any person making a good-faith report.

8. Approval

This statement is reviewed annually and approved by the Board of Kronos Consulting Group LTD.