Modern Slavery Act

Modern Slavery Policy Statement

Almarose Hotels & Resorts are fully committed to ethical and humane working practices, and regard inhumane conditions such as slavery and exploitation as completely unacceptable.

We also recognise our responsibilities and encourage our suppliers to operate in a way that minimises their impact on the local environment and protects the welfare of those employed by them.

This policy sets out Almarose Hotels & Resorts' approach to Anti-Slavery, Human Trafficking and Ethical Trading. The provisions in this policy apply to all colleagues, workers, contractors, suppliers and other business partners.

Understanding Modern Slavery

Modern slavery is a crime and a violation of fundamental human rights.  It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.  We have a zero tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships; to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

This policy sets out the provisions that Almarose Hotels & Resorts have in place to identify, understand and prevent the risk of slavery or human trafficking in our own business and our supply chains.

General Principles

We are committed to ensuring there is transparency in our business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.  We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect our suppliers to hold their own suppliers to the same high standards.

Prevention of Slavery and Human Trafficking in Almarose Hotels & Resorts

In order to detect and prevent acts of slavery within our business, we have a number of policies and practices in place.

Eligibility and Right to Work Checks

All colleagues employed by Almarose Hotels & Resorts to work on either a temporary, fixed term or permanent basis are subject to a right to work check in line with the provisions of the UK legislation.  A person is unable to commence work for Almarose Hotels & Resorts unless they satisfy us that they are legally able to work within the UK.

All recruiting managers must ensure that they undertake the right to work check upon offering a position and that an offer of employment is only made once it has been confirmed that the prospective colleague is able to legally work in the UK.

Should it subsequently transpire that a worker used false documentation to satisfy the right to work check, the appropriate action will be taken under the disciplinary policy which may include dismissal.

Resourcing

Where Almarose Hotels & Resorts employs the services of employment agencies from time to time to source candidates for permanent or fixed term positions, we endeavour to only use agencies of good repute and who are generally listed on our preferred supplier list. Whilst Almarose Hotels & Resorts expect the agencies to undertake the appropriate background checks on prospective colleagues, recruiting managers must still conduct right to work checks and be satisfied of the candidate's legal right to work in the UK prior to an offer of employment being made either on a temporary or permanent basis.

Agency Workers

Where Almarose Hotels & Resorts uses temporary workers supplied through employment agencies, we expect and require that the agency has undertaken appropriate checks.  We operate a preferred supplier list for these agencies and those listed are expected to adhere to our standards on the prevention of slavery and human trafficking.

In the event that Almarose Hotels & Resorts identifies that an employment agency is not adhering to our standards, the agency will be removed from the preferred supplier list and will not be engaged in any further recruitment activity on any basis.

If a manager believes that an employment agency is not adhering to Almarose Hotels & Resorts' standards, they should inform their Regional Human Resources Manager immediately so the appropriate action can be taken.

Whistle-blowing Policy

We are committed to conducting our business with honesty, integrity, and accountability and we expect all colleagues to maintain these high standards and encourage a culture of openness and accountability in order to prevent and/or to address issues when they do occur.  Therefore, we expect any colleague who has concerns about any aspect of our work including our provisions for anti-slavery and human trafficking, both internally and within our supply chain, to disclose their concerns in accordance with the whistle-blowing policy, which is available on e-vista.

The whistle-blowing policy applies to all employees, casual workers, agency staff, contractors, subcontractors, agents, sponsors, suppliers or any other person associated with Almarose Hotels & Resorts.

Prevention of Slavery and Human Trafficking in Almarose Hotels & Resorts Supply Chains

Almarose Hotels & Resorts will never knowingly accept food or other products from suppliers who exploit the people or natural resources of their environment.  To this end, if Almarose Hotels & Resorts becomes aware of any concerns with one of our suppliers we will investigate and determine whether these concerns are justified, and take the appropriate action to address the issues.  This could involve working with the supplier to agree an action plan to address the issues, delisting the supplier, and/or sourcing product from an alternative supplier, all dependant on the nature and severity of the concerns.

Almarose Hotels & Resorts recognises the importance of establishing trustworthy supplier relationships and continues to develop clear ethical standards to ensure our suppliers can demonstrate that they have taken all reasonable efforts to assess the vulnerability of their individual supply chains to poor ethical conduct, including modern day slavery and deceptive work practices.

Our current approach involves gathering information on a prospective new supplier's ethical controls through a supplier self audit questionnaire (SAQ).  This is assessed by the Procurement Director and should our Procurement Department decide to progress with them as a supplier, the ethical working practices of suppliers will continue to be reviewed regularly and on an ongoing basis.

All new suppliers will be assessed and existing suppliers measured for compliance, which determines the level of ethical risk at each stage of the supply chain.  Effective escalation processes are in place to support decision-making should we become aware of non-compliance.  Suppliers will be required to undertake an independent ethical audit of their full supply chain should it be deemed necessary by risk assessment.  The outcome of such an audit is used to determine whether we will work with a supplier.

Suppliers' ethical performance will be monitored on an ongoing basis at a frequency determined by the level of risk and vulnerability within their supply chain and we will continue to review the effectiveness of these controls in reducing the risk of unethical practices.

Responsibility for the Policy

The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under their control comply with it.

The Procurement Director and the Chief People Officer have primary responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy and the issue of modern slavery in supply chains.

Updated January 2020 (financial year ending December 2019)