Statement on Slavery and Human Trafficking
Gem Hotels are committed to improving our procedures to combat slavery and human trafficking both within our own business and that of our supply chains. As part of our due diligence processes we shall make enquiries with all new suppliers as to the mechanisms they have in place to combat slavery and human trafficking and we will require all new suppliers to express their commitment to comply with the Modern Slavery Act 2015.
We are a collection of private luxury hotels located in London. We have circa 2000 employees and primarily operate within the UK.
We have a zero tolerance approach to modern slavery and human trafficking and we are committed to ensuring that it has no presence in our supply chains or in any part of our business. We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place.
Our internal policies and employment procedures are reviewed regularly to ensure compliance with the Modern Slavery Act 2015. Particular policies relevant to the combating of modern slavery and human trafficking include our Procurement Policy (which establishes our supplier selection methodology) and Whistleblowing Policy (designed to encourage and protect any member of staff who wishes to raise any concerns related to the activities of the firm).
Due Diligence Processes
Our recruitment processes are transparent and reviewed regularly. We communicate directly with candidates to discuss job opportunities and to confirm the details of any offer made and work only with reputable recruitment businesses. We have robust procedures in place for the vetting of new employees and ensure that we are able to confirm their identities and that they are paid directly into an appropriate, personal bank account.
We have fairly extensive supplier relationships. Each outsourced service supplier is carefully considered as are other suppliers when awarding or renewing business. We review our suppliers on a regular basis and have committed to work with organisations who share our values. We monitor and review the controls undertaken by our suppliers and now require, from our key suppliers, an annual statement of their commitment to our Supplier Code of Conduct.
We are conscious that imported products or services sourced from outside the UK or EU are potentially more at risk of slavery or human trafficking issues. If products have to be sourced from such locations, we will look to those suppliers who can demonstrate a commitment to human rights and fair working conditions.
We will not work with any supplier organisation that has been found to have been knowingly involved in either human trafficking or modern slavery.
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 staff as part of their induction and provide refresher training as appropriate.
Our Supply Chains
We have long standing relationships with our supply chains the majority of whom also operate within the UK but we do contract with suppliers from or whom operate in other jurisdictions.
Our Effectiveness in Combating Slavery and Human Trafficking
We shall undertake annual review of the effectiveness of the steps we have taken to ensure that here is no slavery or human trafficking in our supply chains with a view to identifying further steps that we can take.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement of Gem Hotels.
The statement has been approved by the Directors who will review and update it as necessary on an annual basis.