Modern Slavery and Human Trafficking Statement
This statement is published by Cairn Group, in compliance with the UK Modern Slavery Act 2015. This statement details the steps taken by Cairn Group to identify and take steps to prevent modern slavery and human trafficking in all parts of its business and supply chains during the Financial Year 2021.
For the purposes of this statement, the companies conducting business within the United Kingdom, are collectively referred to as “Cairn Group” include Station Hotel (Newcastle) Ltd.
At Cairn Group we take seriously our responsibility to help prevent the crime of modern slavery and human trafficking across our own business as well as that of our partners and suppliers.
OUR BUSINESS STRUCTURE AND SUPPLY CHAIN
Cairn Group is a national hospitality company with a portfolio of 10 brands in addition to non-branded venues comprising more than 30 properties with approximately 1700 employees.
Cairn Group develops and negotiates product and service supply programs with more 1500 suppliers across our venues that make available goods and services at the best combination of price, quality, and service.
OUR COMMITMENT TO HUMAN RIGHTS
At Cairn Group we are passionate about delivering the highest levels of service and we want our employees experience of working to be both positive and rewarding. It’s our objective is to meet the needs of our guests whilst also providing our staff with job satisfaction whenever possible.
Our employment policies and procedures aim to make sure everyone is treated fairly and consistently. We look to inspire a working environment in which equality, diversity and human rights are recognised, valued and encouraged.
Our commitment to respecting human rights is detailed in our Equalities, Diversity and Human Rights policy. Human Rights Policy is shared with all our employee. Additionally, all our human rights-related trainings, guidance, tools are available to all employees and refreshed periodically.
The responsibility for human rights ultimately sits with Aran Handa, who sits on the Executive Committee. Our corporate responsibility priorities, including human rights risks, strategy, policies, are reviewed by the Board annually.
As part of our commitment, we ensure that our workers are not being exploited, that our work environment is safe, and that all employment, health & safety and human right laws are fully adhered to.
Our Human Rights Policy embodies and reinforces our commitment to these and other key guiding principles, and applies to all Cairn Group (including Station Hotel (Newcastle) Ltd) companies as well as to our partners and suppliers.
Cairn Group acknowledges and respects the principles contained in the Universal Declaration of Human Rights, and this Human Rights Policy reflects the Company’s commitment to conduct its business in a manner consistent with these principles, and to protect human rights within the company’s sphere of influence. The Company demonstrates responsible workplace practices, and endeavours to conduct its business operations in a manner that is free from complicity in human rights abuses. The Company is committed to ethical business practices and good corporate citizenship, and acknowledges supports and protects human rights wherever it can. As a responsible Company, we believe that strong ethics and good business go hand in hand. The Company is committed to complying with all applicable human rights laws and regulations and our Human Rights Policy is available to all employees.
To demonstrate our commitment to human rights we:
- Support the protection of human rights, particularly those of our colleagues, the parties we do business with and the communities where we operate
- Provide a safe and healthy working environment
- Support the elimination of employment discrimination and promote diversity in the workplace
- Provide our colleagues with remuneration and tools for their roles, and take their well-being into consideration
- Conduct our business with honesty and integrity in compliance with applicable laws
- Develop and implement company procedures and processes to ensure we comply with this policy.
- Do not support forced and compulsory labour or the exploitation of children
ETHICAL BUSINESS CONDUCT
We require that business be conducted with honesty and integrity, and in full compliance with all applicable laws. Company policies establish clear ethical standards and guidelines for how we do business and establish accountability. All company employees are required to obey the law and comply with specific standards relating to legal obligations, ethics, and business conduct.
As part of our procurement process, we periodically vet our partners and suppliers to identify and help prevent potential modern slavery or human trafficking risks in our supply chain. We expect our partners and suppliers to ensure that they either have equivalent policies to ours or that they abide by our policies.
OUR DUE DILIGENCE PROCESSES – RISK IDENTIFICATION
Upon reviewing our business practices across the UK, our assessment identified the following principle modern slavery risks:
- Our employees may be in situations of working excessive hours or bonded labour excised by external parties.
- Our venues may be used by criminals to traffic victims for sexual exploitation or as halfway houses in the movement of victims.
- Individuals employed via a recruitment agency or a labour outsourcing agency, or by other goods or services suppliers may be in a situation of forced / bonded or child labour as a result of a range of potential factors, from excessive recruitment fees to failure to pay National Minimum wage.
- Construction workers employed by appointed contractors may pose situations of forced / bonded or child labour as a result of a range of potential factors, from excessive recruitment fees, to restrictions on freedom of movement or failure to monitor workers’ ages.
RISK MONITORING AND MITIGATION
Our mitigation response to identified risks:
- We encourage all our employees to raise concerns about potential violations of our Equalities, Diversity and Human Rights policy, including risks of human trafficking or modern slavery, to their manager. Alternatively, these can be reported directly to Head Office. We monitor all earnings to ensure that minimum wage payments are met and no unlawful deductions are made from pay. All employees are expected to be vigilant for suspicious and unusually behaviour within their teams. All incidents are investigated and logged by the HR department. Any trends are identified with the purpose of applying more focused examination and implementation of preventative measures.
- All Team Members are required to report safety or reputational incidents, including potential situations of modern slavery, via their duty Manager, Modern Slavery helpline or Police depending on the situation. Advice and training is given to all new employees and existing employees refreshed periodically.
- We understand some external organisations may use our Company to fraudulently recruit individuals. We do not charge recruitment fees and expect our business partners to do the same. Wherever possible, Cairn Group hires candidates directly and all employment contracts are issued directly by us. We do not use 3rd parties to issue employment contracts.
- Suppliers are encouraged to have appropriate management systems in place and take steps to comply with this. They must undergo due diligence and compliance checks, including initial screening on human rights, before agreements or partnerships are made.
- We carry out due diligence reviews on our labour supplies, including a human rights reputational review and the transmission of our Human Rights policies to all potential agents.
TRAINING AND AWARENESS
Mandatory training is required of all our staff with respect to Modern Slavery, Equality & Diversity & Health & Safety, with further safeguards in place such as right to work in the UK compliance, National Minimum Wage compliance, Working Time Directive compliance in addition to policy information detailed with the Employee Handbook. Additional support can be obtained from the Human Resources team.
This statement was approved by Aran Handa (Company Director) on 07/04/2021.