MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

This statement is made on behalf of NLI Operator Limited pursuant to section 54 of the Modern Slavery Act 2015. This statement details the steps taken by NLI Operator Limited in assisting in the prevention of slavery and human trafficking for the year ended 31 December 2018.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour as well as human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit for personal or commercial gain.

 

Organisational Structure 


NLI Operator Limited is registered in the UK, trading as Corinthia Hotel London. The company manages and operates a grand five-star luxury hotel in central London, encompassing a variety of food and beverage outlets and an award-winning spa. Corinthia Hotel London is committed to delivering an uplifting experience to all its clients at every visit. The hotel has an inventory of 283 bedrooms and employs a workforce of over 500 people, most of which are migrant workers.

 

Our Policy 


Corinthia Hotel London strives to promote the rights of every employee and is opposed to modern slavery and human trafficking in all its forms. We are committed to consistently improve and enforce our anti-modern slavery systems and controls thereby ensuring that such activity does not take place in any part of our business and our supply chain.

In its fight against modern slavery, Corinthia Hotel London has introduced an Anti-Modern Slavery Policy and is committed to implementing procedures aimed at identifying, evaluating and regularly reviewing potential risk areas in its operation and supply chains.

The Anti-Modern Slavery Policy is shared with all members of staff. Employees are expected to be aware of, and honour, its content. Whoever breaches the Policy will face disciplinary action potentially resulting in dismissal for misconduct or gross misconduct. We may also terminate our relationship with other individuals and organisations working on our behalf if in breach of this Policy.

 

Due Diligence and Monitoring 


We implemented the following measures to control and minimise the occurrence of slavery within the hotel and its supply chain:

  • An annual review of all wages thereby ensuring that all colleagues are paid at least the minimum wage in line with UK employment law;
  • Integration of our Anti-Modern Slavery Policy into our procurement procedures. We are committed towards ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. We will review our position on an annual basis to ensure continued commitment and development in this area. Corinthia Hotel London has a zero-tolerance policy towards violations of modern slavery law and will terminate supplier agreements deemed to be in violation of it.

 

Responsibility and Training 


Management at all levels, is responsible for ensuring their reports understand and comply with this Statement and are given adequate as well as regular training on it and the issue of modern slavery in supply chain.

The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control.

All colleagues are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chain of any supplier at the earliest possible stage by immediately notifying their Head of Department.

Training on this Statement as well as on the risk our business faces from modern slavery in its supply chain, forms part of the Corinthia Hotel’s Orientation Programme and regular training will be provided as necessary.

 

This statement has been reviewed and approved by the Board of Directors of NLI Operator Limited on 13 June 2019.