Modern Slavery & Human Trafficking Statement

 

Introduction
This statement sets out Champneys's actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2018 to 31 March 2019.
As part of the hospitality industry, Champneys recognises that it has a responsibility to take a robust approach to slavery and human trafficking.
Champneys is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains
Champneys Henlow Limited is one of the UK's leading privately owned hospitality group for health & wellbeing spa resorts and hotels. This Statement is made in respect of the operations of Champneys Henlow Limited. Champneys head office is located in Henlow, Bedfordshire.
The group consists of over 4 health and wellbeing resorts, 2 hotels, 6 city spas, and a college in the UK. The focus of our business is people, and our responsibility begins with the way we treat our staff and invest in their potential through training and personal development. The business relies on the services of around 1,400 workers spanning beauty therapist, food and beverage operations; housekeeping; guest service operations; kitchen operations and fitness operations. We also have employees in commercial and finance operations; hotel operations and in administration, IT, marketing and HR roles.


Countries of operation and supply
The organisation currently operates in the following countries:
•    United Kingdom. 

Relevant policies
Champneys operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations;
•    Whistleblowing policy: Champneys encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can email humaresources@champneys.com in confidence. 
•    Employee code of conduct: Champneys code of conduct makes it clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
•    Supplier/Procurement code of conduct:  Champneys is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Champneys works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the Champneys supplier code of conduct will lead to the termination of the business relationship. Before any commitment to work with a supplier, we ensure all of our suppliers have a robust modern slavery & human trafficking statement. 
•    Recruitment policy: Champneys uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.   We ensure we operate and recruit ethically and in line with current legislation.  

Due diligence
Champneys undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. Champneys due diligence and reviews include:
•    Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
•    Evaluating the modern slavery and human trafficking risks of each new supplier; 
•    Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
•    Conducting supplier audits or assessments through Champneys own staff, which have a greater degree of focus on slavery and human trafficking where general risks are identified;

Training
Champneys will use the following KPIs to measure how effective we have been to ensure that slavery and human trafficking is not taking place in our business or supply chains:
•    Any and all incidents or complaints of slavery and human trafficking reported, whether under our Whistleblowing Policy or otherwise, are investigated within 24 hours.
•    Monitoring the response rate of "at risk" suppliers to our request that they advise us on the steps taken to ensure slavery and human trafficking is not taking place in their business or supply chains.
•    Ensure we train staff on our Anti-Slavery Policy and our Whistleblowing Policy;
•    Remedial action taken following non-compliances found during audits.


Awareness-raising programme and future commitment
As well as training staff, Champneys has raised awareness of modern slavery issues by ensure our statement and policies are fully available for all employees to access in our policy document library via our employee HR portal. 
Champneys believes in increased transparency in how we are playing our part in preventing slavery and human trafficking. We will continue to monitor the effectiveness of our compliance programme and take necessary steps to address any instances of slavery and human trafficking on an ongoing basis. We will publish an updated Modern Slavery Act Transparency Statement in each financial year.

Board Member approval
This statement has been approved by the Champneys board of directors, who will review and update it annually.
 

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