MODERN SLAVERY & HUMAN TRAFFICKING TRANSPARENCY STATEMENT
January 2017 – December 2017
Principal Hotel Company acknowledges its responsibilities under the Modern Slavery Act 2015,
making a voluntary commitment to ensure acts of slavery, human trafficking, child and sexual
exploitation do not occur across its operating businesses, and those within its suppliers of goods and
services. This statement relates to actions and activities during the financial year ending 31
st
December 2017.
Principal Hotel Company is the trading name of a collection of companies (the Group) which, during
the financial year, operated 42 Hotels/Venues across two divisions, ‘Principal’ and ‘De Vere’ providing
accommodation, food and beverage, conference and events services, leisure clubs and spas. The
group consists of a number of operating and holding companies. A list of the operating companies for
the financial year can be found in the Appendix to this statement. The parent company of the group is
Principal Hotels Topco 1 Limited.
Our Supply Chains
Principal Hotel Company has relationships with external businesses to support the running of the
hotels and venues as follows:
Arrangements to supply agency workers to supplement hotel staffing needs, as and when
required.
Arrangements for the supply of goods and services (some by contractors) to the hotels.
Policies & procedures relating to the prevention of Modern Slavery and Human Trafficking.
Principal Hotel Company first made a Modern Slavery Statement in the financial year ending 31
st
December 2016. Since then, the Group has continued to progress and taken the following steps to
reduce the risk of modern slavery existing in our business and supply chains.
Reviewed the previously identified areas within the business and supply chain that may be at
risk of modern slavery, human trafficking, child and sexual exploitation occurring. This review
concluded that there were no changes to areas of risk previously identified.
As part of the Group’s due diligence processes to avoid slavery and human trafficking, a number of
policies and procedures exist. These include, but are not limited to:
a) Ethical Recruitment
Require the HR teams and those colleagues who are delegated the responsibility for the
recruitment of colleagues, to understand their responsibilities correctly by carrying out ‘right to
work’ checks, and therefore ensure legal compliance. This requires full ID checks to take place
including passports and, where relevant, work permits.
During 2017, the Group introduced a new process to centrally audit this information on a regular
basis to ensure the policy is rigorously implemented across the Group.
As part of the Group’s due diligence, all potential providers of agency workers are required to
complete and sign a declaration confirming that they are fully compliant with the requirement of
UK Immigration legislation and the Modern Slavery Act. This necessitates agency worker
providers to respond to set questions to which responses are assessed to ensure 100%
compliance before approving providers of agency workers.
A central register of approved Agencies has been set up and as part of this process, face to face
meetings have been held by the Group’s Head of Talent with all agency worker suppliers and
recruitment agencies. The purpose of these meetings was to reinforce our policy, ensure full
understanding and compliance with their obligations and to reinforce the Group’s zero tolerance
approach to modern slavery and human trafficking.
b) Whistle Blowing
The Group at all times conducts its business with the highest standards of integrity and honesty.
It expects all colleagues to maintain the same standards in everything they do. Colleagues are
therefore encouraged to report any wrongdoing by the Group or its colleagues that falls short of
these business principles. To support this, a totally confidential and independent whistleblowing
call service continues to be available to all colleagues.
c) Management of suppliers to prevent Modern Slavery within the Supply Chain.
All potential suppliers continue to be required to complete a ‘New Supplier Questionnaire’ as part
of the process to seek approval to supply the Group. This includes the requirement to confirm
their compliance with the Modern Slavery Act. In addition, potential suppliers must agree to the
Group’s right to inspect their premises, manufacturing, processing and storage facilities. Initial
audits have been performed on the Groups behalf to review all aspects of the supply chain,
including safety, working practices and other legal requirements.
Imported goods from sources from outside the UK and EU are potentially more at risk of slavery
and human trafficking issues. The Procurement department for the Group constantly review the
supply chain to evaluate such risks.
d) Training
The Group recognise that Hotels may be used as temporary accommodation to support the
exploitation of vulnerable adults and children. The Group developed and cascaded a training
programme to make colleagues aware of potential risks so that colleagues can demonstrate
vigilance in spotting possible cases of slavery, human trafficking or sexual exploitation on our
premises, by recognising the signs to look for and how to report such activities. This training has
been ongoing throughout 2017.
Modern Day Slavery training is now also included in the 2 day Induction programme that all new
colleagues attend within their first week of joining the Group.
Measuring Effectiveness
The Group is pleased to report that in one hotel location, local police have ‘tested’ our hotel team
undercover and the actions taken by the hotel team were deemed to be highly satisfactory.
Spot checks have been undertaken by our central compliance team, internal HR teams and our
central procurement team to test aspects of our policies and procedures and the effectiveness of our
training.
The Group has also worked extensively with the Shiva Foundation, supporting and contributing to
their Modern Day Slavery awareness initiatives and raising the awareness of the work they have
undertaken for the benefit of the entire hospitality industry.
The Board of Directors has overall responsibility for ensuring this policy complies with our legal and
ethical obligations. This includes, but is not limited to, preventing the use of Group premises for the
sexual exploitation of adults and children; recruitment of employees or agency workers via
unauthorised agencies or subcontracted; and the purchasing of goods or services from non-approved
suppliers, exposing the Group to the potential risk of indirectly supporting unethical employment
practices such as forced or bonded labour.
All colleagues are required to support the Group’s commitment to Anti-Slavery & Human Trafficking
prevention measures at all times. Since November 2016, this commitment has also become a
condition of employment for all new Managers and Executives of the Group.
Further colleague information regarding the prevention of modern slavery and human trafficking is
also outlined in our Colleague Handbook and Inspire Online, our e-learning portal.
The Group will not knowingly support or deal with any business involved in slavery, human trafficking
and child or sexual exploitation.
This policy statement has been reviewed and approved by the Board of Directors and will be reviewed
and published annually.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our
Group's slavery and human trafficking statement for the financial year ending 31
st
December 2017.
_________________________________
Tony Troy
Chief Executive Officer
Principal Hotel Company
APPENDIX
Companies which operate hotels and conference centres
Company name
Company
number
De Vere Cotswold Water Park Limited
3987970
De Vere Grand Connaught Rooms Limited
6809588
De Vere Selsdon Estate Limited
4977813
De Vere Limited
1396936
De Vere 2 Limited
2025334
De Vere Oxford Thames Limited
2944262
De Vere Tortworth Court Limited
3745617
De Vere Wokefield Estate Limited
7430305
Oxford Spires Hotel Limited
3629986
The Derbyshire Hotel Derby Limited (sold 31 October 2017)
6291448
The Grand Central Hotel Glasgow Limited
6874962
The Met Hotel Leeds Limited
4977435
The Principal Edinburgh George Street Limited
5425343
The Principal London Limited
4977433
The Principal Manchester Limited
4977164
The Principal York Limited
4977629
The St David's Hotel Cardiff Limited
3299012
The St Johns Hotel Solihull Limited (sold 30 November 2017)
6311941
Property companies
Company name
Company
number
Alexandra House Properties Limited (sold 31 August 2017)
5965421
Beaumont House Properties Limited
5971173
Castlewood Property Management Limited
3215195
Castlewood Securities Limited
6082575
Cranage Hall Properties Limited
5940107
De Vere Venues Properties Limited
5622843
De Vere Wokefield Property Limited
6448766
Eastwood Hall Properties Limited (sold 31 August 2017)
5940087
Ettington Chase Properties Limited (sold 31 August 2017)
5944125
George Hotel Investments Limited
5451630
Grand Central Hotel Company Limited
6874981
Grand Principal Birmingham Limited
10521069
Horwood House Properties Limited
59469580
Lagonda Leeds Propco Limited
4216823
Lagonda Palace Propco Limited
4216858
Lagonda Russell Propco Limited
4216881
Lagonda Selsdon Propco Limited
4216938
Lagonda York Propco Limited
4216858
Sedgebrook Hall Properties Limited (sold 31 August 2017)
5944123
Venice Spareco Limited
5894320
Wotton House Properties Limited
5965427
Group central services
Company name
Company
number
Principal Hayley Limited
6137931
Non-trading companies
Company name
Company
number
Principal Hotels Topco 1 Limited (Parent)
9357457
Castlewood Utilities Ltd
6082575
De Vere Venues Group Limited
6139080
De Vere Wokefield Park Limited
6448669
De Vere W Park Limited
6718572
DVV Holdco Limited
8813573
DVV Investco Limited
8813674
DVV Properties 2 Limited
9670573
Four Pillars Hotels Limited
1303927
Hadrian Bidco 1 Limited
6198404
Hadrian Bidco 2 Limited
6220852
Hadrian Bidco Limited
6198387
Hayley Conference Centres Acquisitions Limited
5576842
Hayley Conference Centres Enterprise Limited
5947002
Hayley Conference Centres Group Limited
3908294
Hayley Conference Centres Holdings Limited
5436673
HCC Group Properties Limited
5971189
HCC Properties Limited
5946999
Lagonda George Holdings Limited
5452202
Martins Bidco Limited
9929546
Milan Newco 1 Limited
9669562
Milan Newco 2 Limited
9669909
Oxford Witney Hotel Limited
2200412
Principal Hayley HP Limited
3977187
Principal Hayley Group Limited
4977436
Principal Hotel Company Limited
9358450
Principal Hotels Topco 3 Limited
9359772
Quad Bidco Limited
8821600
Quad Holdco Limited
8821509
Rome Holdco Ltd
8373863
Rome Investco Ltd
8374006
Spire Bidco Hotels Limited
7146956
Venice Bidco 1 Limited
5839374
Venice Hadrian 4 Limited
6198392
Venice Newco 1 Limited
5839399
Venice Newco 2 Limited
5879450
Venice Spareco 2 Limited
5947281
Vocalhaven Limited
2189787
