Starboard Hotels Ltd - Modern Slavery and Human Trafficking Statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our business’s slavery and human trafficking statement for the financial year ending 30 June 2020.

About Us

Starboard Hotels Ltd is a company registered in England and Wales and whose registered office is at Park House, 10 Penn Road, Beaconsfield, HP9 2LH

The principal activity is the operation and management of hotels. At the time of writing this statement, the business has 21 hotels and 360 employees across the various entities.

Hotel locations are in Barnsley, Birmingham, Blackpool, Burnley, Crewe, Derby, Gatwick, Greenock, Haydock, Leeds, Leicester, London, Plymouth, Ramsgate, Sheffield, Tamworth, Teignmouth, Wetherby, and Windermere.

Our Central Offices are based in Beaconsfield and Chorley.

Definitions

Starboard Hotels Ltd considers that modern slavery encompasses:

• Human trafficking;

• Forced work, through mental or physical threat;

• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;

• Being dehumanised, treated as a commodity, or being bought or sold as property;

• Being physically constrained or to have restriction placed on freedom of movement.

Our Policy & Commitment

We have zero tolerance towards modern slavery, and we are fully supportive of the Modern Slavery Act 2015 and its intention to tackle modern slavery in all its forms, including slavery, servitude, forced labour, child and sexual exploitation and human trafficking. Our policy is that we will act ethically and with integrity in all our business relationships and will implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in connection with our business.

We are committed to monitoring our practices to ensure that slavery and human trafficking, (including child or sexual exploitation) are not taking place in any of our supply chains or in any part of our business. This statement is our public commitment that no such activity will knowingly be permitted, supported, or endorsed through our business or supply chains at any time. We commit to ensuring our business practices are continuously reviewed and checked and we will apply a robust approach to the management of existing suppliers as well as identification and selection processes for all new suppliers to mitigate and manage any risks.

We currently operate nationally across the UK however we acknowledge and recognise the potential for modern slavery to occur regardless of location. We commit to remaining vigilant at all times and to mitigate the risks in all our business activities and within our supply chains.

We commit to developing Starboard Hotels Supplier Code of Conduct through our procurement processes which will set our standards and operating principles.

Supply chains

In order to fulfil its activities, the Starboard Group’s main supply chains include those related to the supply of goods and services from various suppliers in the United Kingdom. We understand that Starboard Hotels first-tier suppliers are intermediary traders and therefore have further contractual relationships with lower-tier suppliers.

Potential exposure

In general, Starboard Hotels Ltd considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

Steps

Starboard Hotels Ltd carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

Starboard Hotels Ltd has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, Starboard Hotels Ltd has taken the following steps to ensure that modern slavery is not taking place:

• reviewing your supplier contracts to include termination powers in the event that the supplier is, or is

suspected, to be involved in modern slavery;

• measures in place to identify and assess the potential risks in its supply chains;

• undertaking impact assessments of its services upon potential instances of slavery;

• creating action plans to address risk to modern slavery;

• any actions taken to embed a zero-tolerance policy towards modern slavery.

Training

We will communicate the existence of this statement to all staff via our online employee information systems and include it within our Staff Handbook to ensure everyone has a shared understanding. It is also be published on our website.

Impact of Covid-19

During the reporting period covered by this statement, the COVID-19 pandemic had taken hold. For several months, the UK was placed into lockdown to stem the spread of COVID-19. This created several challenges forthe Starboard Group, as it did for others across the nation.

Starboard Hotels Ltd welcomes the UK Government’s decision, as confirmed in April 2020, to allow for a delay of up to 6 months in the publication of modern slavery statements without the risk of facing penalty.

Despite the permitted, delay, Starboard Hotels remains in a position to publish its statement for the financial year 2019/2020 in line with the original publishing requirements.

Starboard Hotels Ltd concludes that the COVID-19 pandemic did not adjust the risk of modern slavery to a level above that which existed before the pandemic.

During the pandemic, the Group’s employees still had access to the grievance procedure to raise any concerns that they may have had.

In line with emergency legislation passed by the Government, Group employees have been paid Statutory Sick Pay during periods of self-isolation where it has not been possible to agree a temporary period of homeworking.

Starboard Hotels Ltd modern slavery risks were subject to the same monitoring procedures during the pandemic as at all other times.

Slavery Compliance Officer

Starboard Hotels Ltd has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to Starboard Hotels Ltd obligations in this regard.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Policy signed by Paul Callingham, Director on 18th June 2021