EXTRACT OF A RESOLUTION signed on 9 February 2022 by the Directors of International Hotel Investments p.l.c. (the "Company") with its registered office address at 22, Europa Centre, Floriana, Malta which is the controlling company of the NLI Group and Corinthia Hotels Limited.
It was RESOLVED to approve the following policy statement:
SCHEDULE 22 ANTI-MODERN SLAVERY POLICY
1. POLICY STATEMENT
1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.
1.2 We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our Anti-Modern Slavery Statement and Code of Conduct. We will review our position on an annual basis to ensure continued commitment and development in this area.
1.3 The Board has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
1.4 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
2. COMPLIANCE WITH THE POLICY
2.1 You must ensure that you read, understand, and comply with this policy.
2.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
22 Europa Centre – Floriana FRN 1400 – Malta – Tel (356) 21233141 – Fax (356) 21234219
e-mail: [email protected] – www.corinthiagroup.com – Co. Reg. No: C26136
2.3 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. Therefore, you must notify your line manager or Head of Department as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
3.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the orientation programme for all individuals who work for us, and regular training will be provided as necessary.
4. BREACHES OF THIS POLICY
4.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
4.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.