PRINCIPAL HOTELS TOPCO 1 LIMITED modern slavery statement summary (2020)

Organisation address
The Inspire,
Hornbeam Square West,
Harrogate,
North Yorkshire,
HG2 8PA

We asked the organisation a series of questions about its modern slavery statement. Its answers are published on this page as a statement summary.

This statement provides information for all 6 recommended topics

What is a modern slavery statement?
UK law requires certain organisations to publish an annual modern slavery statement on their website, setting out the steps they are taking to address modern slavery risks in their operations and supply chains. Read more in the government guidance on publishing modern slavery statements.

PDF version of the statement (optional)

There is no PDF version of this statement.

PDF statements were first introduced to the registry for the 2023 statement year.

About this statement summary

All answers relate to the financial year covered by the statement. The organisation is responsible for all the information it provided. Some of our questions are optional, so organisations may not have answered all of them. The statement summary does not replace the full modern slavery statement – below we provide a link to the full statement on the organisation’s website.

Statement period and sign-off details

The statement covers the following period:
1 January 2019 to 31 December 2019

The statement was signed off by:
James Burrell (chief financial officer)

It was approved by the board (or equivalent management body) on:
31 January 2020

Recommended topics covered by the statement

Government guidance encourages organisations to cover a range of topics in their modern slavery statements, setting out the steps they’re taking to address modern slavery risks in their operations and supply chains. Read about the recommended topics in the statutory guidance.

We asked the organisation to tell us which topics its statement covers.

Topics recommended by government guidance Organisation’s response
The organisation’s structure, business and supply chains Covered
Policies Covered
Risk assessment Covered
Due diligence (steps to address risk) Covered
Training about modern slavery Covered
Goals and key performance indicators (KPIs) to measure the effectiveness of the organisation's actions and progress over time Covered

The organisation’s sectors and turnover

Sectors

The organisation operates in the following sectors:

  • Hotels and Hospitality

Turnover

Its turnover in the financial accounting year of this statement was:

Under £36 million

If the organisation is a public body, this amount is based on the organisation’s budget for the year of the statement.
What does 'turnover' refer to in group statements?
If this is a group statement, this includes the total turnover for all the organisations covered by the statement.

Number of years producing statements

The organisation has been producing modern slavery statements for the following number of years:
1 to 5 years
How does this work for group statements?
If the statement is for a group of organisations, this answer applies to the organisation with the longest history of producing statements.

Policies (optional)

We asked the organisation whether its policies include the following provisions in relation to its domestic and international supply chains, as well as its own operations.
Organisation’s response
The organisation told us its policies do not include any of the provisions we listed in our question.

Training (optional)

We asked the organisation whether it provided training on modern slavery, and who it was for.
What counts as training?
We explained that by ‘training’ we meant anything designed to increase knowledge and skills around identifying, addressing or preventing modern slavery risks. This could range from formal training courses to broader awareness-raising activities such as workshops or webinars.
We asked who the training was for Organisation’s response
Your whole organisation Yes
Your front line staff Yes
Human resources Yes
Executive-level staff Yes
Procurement staff Yes
Your suppliers No
The wider community No
Other
No

Monitoring working conditions (optional)

Engaging with others

We asked the organisation to tell us who it engaged with to help monitor working conditions across its operations and supply chains.
We asked who the organisation engaged with Organisation’s response
Your suppliers Yes
Trade unions or worker representative groups No
Civil society organisations No
Professional auditors No
Workers within your organisation Yes
Workers within your supply chain No
Central or local government No
Law enforcement, such as police, GLAA and other local labour market inspectorates No
Businesses in your industry or sector No

Social audits

We asked the organisation to tell us about any social audits it used to look for signs of modern slavery.
What are social audits?
A social audit is a review of an organisation’s working practices from the point of view of social responsibility, and should include an evaluation of working conditions in the organisation’s operations and supply chains. By their nature, audits of supplier workplaces represent a snapshot in time.
Social audits we asked about Organisation’s response
Audit conducted by your staff Yes
Third party audit arranged by your organisation Yes
Audit conducted by your supplier’s staff No
Third party audit arranged by your supplier No
Announced audit No
Unannounced audit No

Grievance mechanisms

We asked the organisation how workers in its operations or supply chains could raise concerns or make complaints.
We asked if workers could raise concerns this way Organisation’s response
Using anonymous whistleblowing services, such as a helpline or mobile phone app Yes
Through trade unions or other worker representative groups No

Other ways of monitoring working conditions

We asked the organisation whether it had any other ways of monitoring working conditions across its operations and supply chains:
Online reporting capturing detailed specific information relating to any given incident. Multimedia evidence including CCTV data capture. KPI reports generated on demand

Modern slavery risks (optional)

Warning Identifying modern slavery risks is a vital step towards eradicating it. The government encourages organisations to be as open and transparent as possible, to improve understanding, collaboration and best practice around tackling this worldwide problem.
We asked the organisation to describe up to 3 priority risks it focused on during the period of the statement, including details of the affected workers, the activity involved, and the location.

Priority risks for this organisation (1 of 3)

Services may be used to exploit vulnerable adults and children, moving them through the hotel or holding them against their will within bedroom accommodation for the purpose of sexual exploitation.
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your own operations.
Who was it most likely to affect Organisation’s response:
  • Women
  • Children
  • Women, childern and vulnerbale adults for purpose of sexual explotaion
In which country Organisation’s response: United Kingdom
Actions or plans to address this risk Organisation’s response: standard operation procedures, training to identify potential l concerns, communications Colleague information regarding the prevention of modern slavery and human trafficking is outlined in our Colleague Handbook and Inspire Online, our e-learning portal.

Priority risks for this organisation (2 of 3)

Some of our properties will be more reliant upon Agency Resource outsource services making it more difficult to constantly monitor their recruitment practices.
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your own operations.
Who was it most likely to affect Organisation’s response:
  • Migrants
In which country Organisation’s response: No details provided
Actions or plans to address this risk Organisation’s response: Established central register of approved agencies. Bi annual Talent Acquisition workshop work shop to re enforce procedures. Colleague information regarding the prevention of modern slavery and human trafficking is outlined in our Colleague Handbook and Inspire Online, our e-learning portal.

Priority risks for this organisation (3 of 3)

There is a possibility that unethical working practice including poor may exist within some aspects of the supply chain; particularly during the manufacturing process. - low pay poor work condition
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • Don't know
Who was it most likely to affect Organisation’s response:
  • unethical working practice including poor working conditions, welfare and pay may exist within some aspects of the supply chain; particularly during the manufacturing process.
In which country Organisation’s response:
  • China
  • United Kingdom
  • Pakistan
Actions or plans to address this risk Organisation’s response: Standard Supplier Questionnaire issued for potential suppliers to be eligible to become an approved supplier. Questionnaire incorporates declaration of compliance with the requirements of the Modern Slavery Act 2015 along with other risk management based declarations. There is a robust Modern Day Slavery Clause in all Group Contracts and Trading Agreements. periodic review meetings with all incumbent Suppliers

Indicators of forced labour (optional)

We asked the organisation whether its statement refers to finding any International Labour Organization (ILO) indicators of forced labour.
What are ILO indicators of forced labour?
The International Labour Organization (ILO) has produced a list of the most common signs of forced labour. They’re based on the definition of forced labour as ‘all work or service which is extracted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.’ More details and guidance are available on the ILO website, and in their publication ILO indicators of forced labour
Organisation’s response
The organisation told us its statement does not refer to finding any International Labour Organization (ILO) indicators of forced labour.

Demonstrating progress (optional)

We asked the organisation how its statement demonstrates progress over time in addressing modern slavery risks. They provided the following answer:
We continue to measure the effectiveness of our Policies and Procedures via a number of direct and indirect indictors detailed in the statement; Training - KPIs Auditing Internal Audits conducted by our Central Support team, including Operational audits on a monthly cycle with department specific parameters conducted by HOD’s and General Managers - KPIs External Audit activity by our Independent Consultants to sample the effectiveness in an unplanned scenario. Reporting