Introduction

Modern slavery and human trafficking are serious crimes and a gross violation of fundamental human rights.

The Modern Slavery Act 2015 defines modern slavery as “slavery, servitude and forced or 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.

Webb Hotel Group is committed to acting in an honest, ethical and responsible manner with transparency in all business dealings. We respect the human rights of every team member and every worker supplying goods or services to us and we take our responsibilities seriously under the Modern Slavery Act 2015. We have a zero-tolerance approach to slavery and human trafficking and we expect the same from our suppliers and contractors.

We are dedicated to understanding the risks so that we can work towards ensuring that there is no modern slavery in our business or supply chains.
This policy applies to all persons working for the Company or on behalf of the Company in any capacity including employees at all levels, directors, agency workers, volunteers, agents, contractors and third-party representatives.

This policy does not form part of an employee’s contract of employment and the Company may amend it at any time.

Responsibility for the Policy

The Company Directors have overall responsibility for ensuring this policy complies with all relevant legal and ethical obligations and that all those under the Company’s control comply with it.

The Group People Manager and the Group Finance Director have 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.

Managers at all levels of the Company are 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.

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 its control.

You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of the Company’s business or supply chains at the earliest possible stage.

You must notify a manager as soon as possible:
• If you believe or suspect that a conflict with this policy has occurred, or may occur in the future
• If you believe or suspect a breach of this policy has occurred or that it may occur
• If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within our supply chains constitutes any of the various forms of modern slavery.

If you do not feel comfortable speaking to a manager you can follow the Company’s Whistleblowing Policy.

The Company encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We aim to ensure that appropriate protections are in place for any colleague who raises a concern, without fear of retaliation.

Communication and Awareness of this Policy

The Company’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of any business relationship with them and reinforced as appropriate thereafter.

This policy is available for all team members on the noticeboard section of Flow/Mapal One. Training on modern slavery forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

The training explains what Modern Slavery is, identifies signs of Modern Slavery and how to report any concerns.

Breaches of this Policy

Any Company employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

The Company may terminate any relationship with other individuals and organisations working on the Company’s behalf if they breach this policy.

Review and Monitoring

We recognise that Modern Slavery and Human trafficking is an area which requires continual monitoring and improvement and we will continue to do this.

Last updated 21 November 2023.