Introduction
This statement is made on behalf of Norlake Hospitality Limited and its subsidiaries (as listed below and together, the “Hoxton”) in accordance with section 54 of Modern Slavery Act 2015 (the “Act”) with respect to the financial year ending 31 December 2018.
At the Hoxton, we take our responsibilities to society as seriously as we take our responsibilities to our guests. The Act creates offences in respect of slavery and human trafficking in a range of forms and it is our commitment to do all that we can to combat all such practices in our organisations and supply chains, so as to ensure that our business operations are conducted with integrity and regard for human dignity.
About Us
The Hoxton is a series of six open-house hotels inspired by the diversity and originality of the streets and scenes that surround them. Located in London, Amsterdam, Paris, New York, and Portland, the hotels employ over 700 staff working on site and in head office, and combined, offers over 1000 bedrooms and 12 restaurant and bar concepts. We recognise that modern slavery offences might arise both within our own operations and, due to the nature of our business, within our supply chains.
Our Policies and Procedures
Our current policies and procedures that would assist us in mitigating the risk of such offences arising include the following:
- Recruitment – we conduct checks on any new employees that join our business to ensure that they have eligibility to work in the relevant country, so as to mitigate the risk of human trafficking or of such individuals being forced to work against their will. We also only work with reputable external recruitment partners when looking for new employees.
- Reporting procedures – we have clear avenues in place for all our employees to raise any concerns that they might have in relation to their employment, without repercussions.
- Contractor appointments – our contractor appointment documentation contain general confirmations that contractors comply with all applicable laws, but in addition we also seek extensive specific warranties regarding compliance with the Act from any parties who will be involved in any of our development projects.
- Procurement of goods – where we engage with procurement agents to help source manufacturers or suppliers of goods for purchase for our projects, we ensure that we only engage with reputable agents.
Looking Ahead
In the coming months, we intend to develop a risk-based approach to our procurement of goods strategy, by identifying those of our suppliers that fall within a geographical area or industry that is at high risk of triggering modern slavery concerns, to then take steps to understand their practices and where appropriate to engage with these suppliers regarding the Act.
Approved by the Board of Directors.
Sharan Pasricha, CEO
14 January 2019
