Anti Slavery Policy
This statement is made pursuant to s54 of the Modern Slavery Act 2015 for the financial year ending 29 December 2023, and sets out the steps that Aspen Leisure (“we” or “us”) has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within its business or supply chain.
The Modern Slavery Act 2015 creates offences in respect of slavery, servitude, forced or compulsory labour, and human trafficking ("Modern Slavery"). Aspen Leisure is committed to combatting all forms of Modern Slavery.
Aspen Leisure is committed to operating with integrity and accountability, both within its organisation and in all relationships with suppliers and other partners.
About Aspen Leisure
Aspen Leisure is a privately owned company owning and operating hotel businesses and has its head office in Sevenoaks, England.
The group consists of 1 hotels in the UK. The business relies on the services of around 100 people. As a full-service hotel operator, its activities cover food and beverage production and service, guest reception services, housekeeping delivery, and administrative and accounting functions. The supply chain covers both central supply chains fully administered centrally and hotel-based supply chains overseen from the centre.
Aspen Leisure recognises that Modern Slavery includes the risks that arise from the use of foreign and migrant labour and from supply chains both in the UK and overseas.
Policies and Procedures
Modern Slavery Policy – This 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 are not taking place anywhere in our supply chains.
Code of Conduct for Suppliers - Issued to all suppliers and contractors, the Code requires positive confirmation of compliance. It has been reviewed and updated during the course of 2021.
Recruitment – Aspen Leisure conducts robust checks on any new employee, including eligibility to work in the UK, to safeguard against human trafficking or individuals being forced to work against their will.
Whistleblowing Policy – Aspen Leisure has a whistleblowing policy so that all employees can raise any concerns that they might have without fear of reprisals.
Central Register of Recruitment Agents and Supplier Contracts.
Due Diligence
Aspen Leisure will only work with suppliers who formally confirm full compliance with its policies and exhibit due diligence in monitoring their own supply chains. The demonstration of this compliance is of extreme importance and is verified by risk assessment through random visits to supplier premises and regular review of suppliers, their policies, and monitoring their online and media reputations.
Key Performance Indicators
Number of incidents or complaints of slavery and human trafficking reported under Aspen Leisure’s Whistleblowing Policy or otherwise.
Number of staff trained on Anti-Slavery and Whistleblowing Policies.
Remedial actions required as a consequence of incidents or complaints recorded.
Training for Staff
Training is conducted for team members as part of a new starter’s induction to ensure an understanding of the signs of modern slavery and to explain whistleblowing. Online training modules have been developed and rolled out throughout the business, allowing us to monitor the compliance and understanding of team members regarding Modern Slavery much more easily. In addition, face-to-face training continues to be carried out. All senior managers attend a Health and Safety for Managers course that provides additional training. The topic is reviewed during regular HR team conference calls.
Aspen Leisure has a dedicated compliance team, which consists of involvement from the following departments:
-Legal/Commercial
- Human Resources
- Procurement
Aspen Leisure works with the Shiva Foundation to provide an additional specialist source of best practice, training, and compliance updates.
Future Steps
In the forthcoming year, Aspen Leisure intends to take further additional steps including expanding due diligence on contractors, subcontractors, and suppliers, and regular reviews to monitor the effectiveness of the compliance programme.
This statement was approved by the Board of Directors on 20 June 2024