Modern Slavery and Human Trafficking Statement

Our supply chains

Our supply chains include providers of leasehold property, providers of food and drinks to our venues and providers of facility management services (e.g. IT and other business support services).

Our policies on slavery and human trafficking

We have a zero tolerance approach to modern slavery and human trafficking, and as such we are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Modern Slavery and Human Trafficking 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 slavery and human trafficking is not taking place anywhere in our supply chains. We also have in place a robust whistleblowing policy, designed to encourage and to protect anyone who wishes to raise concerns about wrongdoing within our business.

Due diligence processes for slavery and human trafficking

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. 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 implemented a number of processes to ensure, as reasonably practicable, that our supply chain adhere to our expectations in respect of their workforce.

If we discover that any of our employees have been complicit in human trafficking or modern slavery, we will take the appropriate disciplinary action against them.

We audit our suppliers on a regular basis and have committed to work only with businesses who share our values and who have pledged to assist in the eradication of slavery and human trafficking.

We are conscious that imported products or services sourced from outside the UK or EC are potentially more at risk of slavery or human trafficking issues. If products have to be sourced from such locations, we will look favorably on suppliers who can demonstrate a commitment to human rights and fair working conditions, for example by way of certifications such as Social Accountability certification SA8000.

We will not work with any business that has been found to have been knowingly involved in either human trafficking or modern slavery.

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 will provide training to our staff as part of their induction and provide refresher training as appropriate.

Our effectiveness in combating slavery and human trafficking

The Company Directors and Senior Management shall take the responsibility for implementing this policy statement and its objectives and shall provide adequate resources and investment to ensure that slavery and human trafficking is not taking place within the organisation within its supply chains.

We will continue to monitor and review our policy relating to slavery and human trafficking. If we become aware of any breaches of the policy, we will investigate and take such steps as are necessary to ensure that the risk of further breaches occurring is minimised.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.

Rosemary Squire
Joint CEO and Executive Chairman
Trafalgar Entertainment Group
September 2018