Modern Slavery Policy
Introduction
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.
The Company has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all our business dealings and relationships and 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.
The Company is also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. The Company expects 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 that our suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for the Company or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee's contract of employment and the Company may amend it at any time.
Responsibility for the policy
The Managing Director has overall responsibility for ensuring this policy complies with the Company’s legal and ethical obligations, and that all those under our control comply with it.
The Commercial Director has primary and day-to-day 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.
Management at all levels is responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the General Manager.
Compliance with the policy
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of the Company’s business or supply chains is the responsibility of all those working for the Company or under the Company’s control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify the General Manager of the hotel where you are employed (or the Commercial Director if the General Manager is unavailable or if you would prefer in any event) as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains of any supplier tier at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your General Manager or report it in accordance with the Company’s Whistle Blowing Policy as soon as possible.
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your Line Manager or General Manager.
The Company’s aim is to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. The Company is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform your General Manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.
Communication and awareness of the policy
Training on this policy, and on the risk that the Company’s business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided where necessary.
The Company’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with the Company and reinforced as appropriate thereafter.
Breaches of this policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
The Company may terminate their relationship with other individuals and organisations working on the Company’s behalf if they breach this policy.
Updated: April 2019
1. Introduction from the Group Operations Manager
Modern slavery and human trafficking remain a hidden blight in our global society. We all have a responsibly to be alert to the risks, however small, in our business and in the wider supply chain. All staff of the Company are expected to report concerns and management are expected to act upon them.
2. Organisation’s structure
The Company is a part of the UK chain of Future Inns with hotels in Cardiff, Plymouth and Bristol. Future Inns also operates a chain of restaurants and bars within its hotel facilities. These restaurants and bars are operated as businesses in their own right – with separate identities and ways of working but are managed by Future Inns UK Ltd. This gives us a clear focus on room retailing for our hotels and food and beverage retailing within our restaurant facilities.
The Company’s head office and other business premises are in Cardiff, Bristol & Plymouth, which has 200 employees and carries on business within the UK.
The Company has an annual turnover which is not in excess of £36,000,000.00 but does provide services to customers who do have a turnover in excess of this sum.
3. Our business
Our business is organised into three separate hotels which are in three business locations across the UK in Cardiff, Plymouth and Bristol. Each site provides a restaurant and bar within their own hotel facilities, and also provide additional amenities which include complimentary limited TV and Internet access in every room, free local calls with reasonably priced national calls, meeting facilities, full-service on-site restaurant, free car parking.
4. Our supply chains
Our supply chains include companies which provide goods and services to the hotels such as food and beverage suppliers and those providing cleaning and maintenance.
5. Our policies on modern slavery and human trafficking
The Company is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. The Company’s Anti-slavery Policy reflects 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 and human trafficking is not taking place anywhere in our supply chains.
6. Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk, we have in place systems to:
7. Supplier adherence to our values
The Company has a zero tolerance to modern slavery and human trafficking. We expect all those in our supply chain and contractors to comply with our values.
The Commercial Director is responsible for compliance in their respective departments and for their supplier relationships.
8. Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff. All Directors have been briefed on the subject.
9. Our effectiveness in combating slavery and human trafficking
The Company uses the following key performance indicators (KPIs) to measure how effective we have been to ensure that modern slavery and human trafficking is not taking place in any part of our business or supply chains:
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s modern slavery and human trafficking statement for the current financial year.
Graham Stockman
Commercial Director
Future Inns UK Ltd
