Apex Hotels Group operates eight Hotels across London, Edinburgh, Glasgow, Dundee, and Bath, and a laundry facility operating in Livingston. This statement is made on behalf of Apex Hotels Group, only pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Apex Hotels' slavery and human trafficking statement. We are committed to ensuring that we conduct our business ethically and with integrity. We do not tolerate any forced or compulsory labour or human trafficking and are firmly committed to ensuring that no such behaviour takes place within the Apex Hotels Group.
Our Supply Chain:
Apex Hotels Group has direct relationships with a number of primarily UK based suppliers offering a wide range of products and services.
Our supply chain includes:
- Food and beverage suppliers and hotel operating supplies
- Outsourced systems support and IT services.
- Hotel equipment suppliers and maintenance
- Recruitment and training
- Building supplies and materials
Our commitment extends to our supply chain and our selection of business partners. Our supplier relationships are based on lawful, efficient, and fair practices. We expect our suppliers to operate within the law, adopting practices to treat workers fairly and provide a healthy and safe working environment. We will not knowingly use any suppliers that use forced labour and will only have relationships with suppliers who comply with all laws regarding slavery and human trafficking.
In addition, our suppliers are obliged to pass these requirements on to their subsequent suppliers too and we expect all of their suppliers to monitor their supply chains in order to eradicate modern slavery of any kind. Apex Hotels Group Procurement Department requires Ethical Trading Pledge from our supply chain before engaging in contractual trading ensuring that Employee rights are at the forefront of the suppliers we partner with:
- Employment is freely chosen. i.e., Workers should be free to choose their employment and leave that employment on reasonable notice without hold of financial deposit or personal items.
- Freedom of association and the right to collective bargaining are respected. i.e., Allow workers the freedom of association to join (but not be forced to join), or be represented by, a trade union or similar organisation of their choice, and be free to leave such organisations. Representatives of workers must be elected by the relevant workers, not appointed by management.
- A safe and hygienic working environment must be provided.
- Not use forced, involuntary or underage labour, also support the effective abolition of child labour.
- National minimum wage is paid to all workers. i.e., At least statutory minimum wages (or if none, a realistic living wage) must be paid without discrimination to all workers and all non-statutory deductions must be reasonable and with the consent of the worker.
- Health & Safety, example All personal protective equipment necessary to ensure the health and safety of workers conducting the tasks must be provided free of charge by the employer.
- Provide suitable working conditions and terms and working hours are not excessive. Working hours must not be excessive in line with and allowed by national law.
- Provide a workplace free from discrimination, harassment, violence, or victimisation.
Our Policy and Training:
We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business. Our Modern 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 slavery and human trafficking is not taking place within our business. This policy sits alongside our Whistleblowing Policy which provides a system for our employees to escalate slavery and human trafficking issues and breaches of our Group policies. Both policies are reviewed annually.
Modern Slavery training is provided to all new employees joining our organisation within the induction period and reviewed annually. We utilise The Gangmasters and Labour Abuse Authority (GLAA) resources alongside the Shiva Foundation resources.
Risk Assessment and Due Diligence:
As part of our initiative to identify, monitor and mitigate against industry risk, business transaction risk and recruitment risk, we nominate senior Directors within our business for responsibility for Employee Risk and Supply Chain Risk. We have in place policies and systems across our business to:
- Identify inappropriate employment practice to ensure a focus on eliminating forced or bonded labour
- Identify, assess, and monitor other potential risk areas through our Modern Slavery Risk Assessment and our incident reporting processes
- Mitigate the risk of slavery and human trafficking occurring.
- Protect whistle-blowers.
- Investigate reports of Modern Slavery
Apex Hotels Group continue to keep a focus on Modern Slavery, Human Trafficking and forced or bonded labour and have built key performance indicators to monitor, report and strive to do better.
We encourage anyone with information regarding modern slavery or human trafficking taking place within our organisation or within our supply chain to report this to our Risk and Compliance department by emailing firstname.lastname@example.org or by contacting our HR support service number. We will continue to do everything we can to prevent modern slavery and human trafficking and highlight to our Employees how to identify human trafficking and forced labour issues.
Apex Hotels Group is committed to improve and develop our practices and education in this area to ensure a safe and secure workplace for all.
Managing Director, Apex Hotels Group