The Modern Slavery Statement
This statement is made pursuant to the section 54 (1) of the Modern Slavery Act 2015 and constitutes Super Break Mini Holidays Limited (Super Break’s) slavery and human trafficking statement for the financial year ending 31 March 2018.
This statement sets out Super Break’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 2017 to 31 March 2018.
As part of the travel industry, Super Break recognises that it has a responsibility to take a robust approach to slavery and human trafficking.
Super Break is 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.
Organisation Structure and Supply Chains
This statement covers the activities of Super Break. Super Break is a short break specialist providing 2-5 star hotels, rail travel, Eurostar travel, flights and mini cruises, plus additional extras including theatre, concerts and various other attractions.
Countries of Operation
Super Break currently operates in the United Kingdom but its customers travel to the following countries: Australia, Austria, Belgium, Bulgaria, Canada, Channel Islands, Croatia, Cyprus, Czech Republic, Denmark, Egypt, England, Estonia, Finland, France, Germany, Gibraltar, Greece, Hong Kong, Hungary, Iceland, India, Ireland, Israel, Italy, Jordan, Latvia, Lithuania, Luxembourg, Malaysia, Malta, Monaco, Morocco, Northern Ireland, Norway, Oman, Poland, Portugal, Puerto Rico, Qatar, Romania, Russia, Scotland, Serbia, Singapore, Slovakia, Slovenia, South Africa, Spain, Sweden, Switzerland, Thailand, The Netherlands, United Arab Emirates, United States of America, and Wales.
Risk Assessment Process
The following is the process by which Super Break assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:
- Modern Slavery Act meetings have taken place with key stakeholders across the business.
- Contracts with direct and indirect suppliers include clauses on the MSA Act and we have a zero tolerance for modern slavery and respect for human rights is built into our processes.
- All directly contracted hotel suppliers must comply with our SMS (Safety Management System) audit every 3 years. As part of such audit, suppliers are required to confirm that they have not been convicted of any offence involving slavery & human trafficking, whether through the supply chain e.g. recruitment of staff or by engaging with human traffickers as guests.
High Risk Activities
Super Break does not view any of its activities as being high risk. We are aware that there is a medium or low risk of human trafficking or slavery taking place in relation to hotel construction workers, hotel cleaners, laundry staff, food suppliers, kitchen staff, restaurant/bar staff and rubbish disposal staff. There is also a medium or low risk of a hotel guest being a human trafficker.
Responsibility for Super Break's anti-slavery initiatives is as follows:
- Policies: All relevant policies continue to be reviewed annually and updated where necessary.
- Risk assessments: A risk assessment in the form of a ‘Slavery Risk’ form was distributed from the legal team internally. Any additional risk assessments of the indirect supply chain continues to be under the responsibility of the procurement team at Super Break.
- Training: No further training has taken place during the financial year for senior management. Refresher courses are planned for the next financial year and will be built into the new starter briefing sessions for all new employees to the company.
Super Break operates the following policies that describe its approach to the identification of modern slavery risk and steps to be taken to prevent slavery and human trafficking in its operations:
- Modern Slavery Act Policy Policy In accordance with the MSA Act, Super Break has adopted a group led policy relating to anti-slavery and human trafficking. The policy confirms Super Break’s commitment to tackling slavery and human trafficking throughout our supply chains and to ensure transparency in Super Break’s business. We expect the same high standards from all our contractors, suppliers and other business partners. Super Break includes specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude. The policy is reviewed and updated annually.
- Whistleblowing Policy Super Break has adopted a group led policy relating to Whistleblowing. Super Break encourages all workers, contractors, external consultants, third party representatives, and other business partners to report any concerns related to the direct activities or the supply chains of Super Break. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Super Break whistleblowing procedure is designed to make it easy for workers to make disclosures of any wrongdoing, without fear of retaliation. This policy is reviewed and updated annually.
- Anti-Bribery Policy Super Breaks existing policy is being updated to become a group level policy. This policy outlines how individuals can recognise a situation where bribery might arise and how they should address this.
- Recruitment Policy Super Break has adopted a group led recruitment policy. Super Break 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. Going forward, the Recruitment policy will be drafted to reflect that appropriate consideration has been taken in respect of human trafficking and slavery when recruiting both internal/external employees and contractors.
Super Break undertakes due diligence when considering taking on new indirect suppliers, and regularly reviews its existing indirect suppliers. Going forward Super Break’s due diligence and reviews under the procurement team will include:
- Mapping the indirect 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 indirect supplier by requesting they complete a MSA due diligence questionnaire via Super Break procurement e-sourcing platform before participating in an RFI or RFP process;
- Create a risk profile for each indirect supplier, where appropriate, based on the response within the MSA due diligence questionnaire;
- Invoking sanctions against suppliers that fail to improve their performance in line with an action plan, including the termination of the business relationship and
- Insertion of a MSA Act focussed legal clause in our supplier contracts. Contracts with suppliers will include clauses on the Act and risk factors. Zero tolerance for modern slavery and respect for human rights will be built into supplier contracts and also be represented in dialogue with sub-contractors, customers and other business partners.
Super Break plans to roll out a refresher awareness-raising programme by circulating updated and new policies including the Anti Slavery and Human Trafficking policy, along with a briefing to all staff.
The briefing will explain to staff:
- The basic principles of the MSA Act and how it impacts Super Break
- How employees can identify and prevent slavery and human trafficking; and
- What employees can do to flag potential slavery or human trafficking issues to the relevant parties with Super Break.
This statement has been approved and signed off by Super Break board of directors who will review and update it annually.
Update May 17, 2019