Modern Slavery Act

MACDONALD HOTELS LIMITED

MODERN SLAVERY ACT TRANSPARENCY STATEMENT

 

INTRODUCTION

This is the modern slavery transparency statement (the “Statement”) of Macdonald Hotels Limited ("Macdonald Hotels") for the financial year ending 28 September 2023. This statement is made pursuant to s.54(1) of the Modern Slavery Act 2015 and details Macdonald Hotels’ commitment to preventing modern slavery and human trafficking within its business and that of its subsidiaries (the “Macdonald Hotels Group”).

Macdonald Hotels is committed to operating with integrity and accountability in all of our business practices - a commitment that applies not only to Macdonald Hotels Group but also to our relationships with suppliers.

We adopt a zero-tolerance approach to slavery and human trafficking. We are committed to taking all reasonably practicable steps to ensure that slavery and human trafficking is not present either in our operations or supply chains.

Macdonald Hotels recognises that slavery and human trafficking are not issues isolated to the overseas hospitality sector. In particular, we recognise that risks arise from the use of foreign and migrant labour, and from supply chains both in the United Kingdom and overseas.

ABOUT MACDONALD HOTELS

Our business

Macdonald Hotels Group is one of the United Kingdom's leading privately-owned hotel and hospitality services businesses, headquartered in East Kilbride, South Lanarkshire, Scotland.

Macdonald Hotels Group owns and operates more than 30 luxury hotels and resort properties, with related hospitality, spa, golf and leisure facilities, across the United Kingdom and Spain. The core and focus of our operations is our people. Our ethical responsibilities begin with the way in which we treat our personnel and the ways in which we invest in their potential and growth through continuous training and personal development. We rely on the services of around 2,500 personnel covering our food and beverage operations, housekeeping, guest services, kitchen operations, recreational, spa and leisure operations, property managerial operations, as well as our central functions including our commercial, corporate and finance operations, IT infrastructure, legal, procurement, marketing, sales and revenue, and human resources.

POLICIES AND PROCEDURES

In implementing Macdonald Hotels’ commitment to ethical practices, we operate a compliance programme comprising policies, procedures and requirements for employees and suppliers which includes human rights, ethical practices and modern slavery. The programme requires robust checks and verification in respect of migrant workers; a whistleblowing policy to encourage personnel to report instances of unethical conduct; and a central register of recruitment agents and supplier contracts. We only work with trusted agents and suppliers and we require all candidates to evidence their right to work in the United Kingdom prior to commencement of employment.

In direct response to the risk of slavery and human trafficking, Macdonald Hotels has built upon its existing compliance framework by:

• Updating our Whistleblowing Policy to ensure coverage of suspected slavery and human trafficking incidents;
• Amending and implementing our Anti-Slavery Policy so that it can be shared with our suppliers and recruitment agencies;
• Taking external legal advice, where applicable, on the application of the Modern Slavery Act 2015 within our business;
• Communicating our senior management’s strong support for the aims of the Modern Slavery Act 2015 and our zero tolerance approach to slavery and human trafficking;
• Conducting a risk assessment of our business and our supply chains (as detailed below); and
• Identifying key performance indicators against which to assess our progress in managing the risks of slavery and human trafficking in our business and our supply chains (as detailed further below).

DUE DILIGENCE IN OUR SUPPLY CHAINS

As part of our zero tolerance approach to slavery and human trafficking, Macdonald Hotels will only work with those who provide assurances on their working practices and commitment to combating slavery and human trafficking in their own businesses and supply chains.

We endeavour to conduct regular risk assessments of our supply chain. Where we identify suppliers to be “at risk” of slavery and human trafficking, we will seek compliance assurances from them, and ensure the right to terminate any agreement early for failure to comply with applicable laws and our Anti-Slavery Policy.

KEY PERFORMANCE INDICATORS (“KPIs”)

We will use the following KPIs to measure how effective we have been to ensure that slavery and human trafficking is not taking place in our business or supply chains:

• Any and all incidents or complaints of slavery and human trafficking reported to Macdonald Hotels’ Legal Department, whether under our Whistleblowing Policy or otherwise, to be investigated within 24 hours;
• Monitoring of the rate of response from “at risk”-categorised suppliers who have been asked to promptly advise on the steps taken to ensure that slavery and human trafficking is not taking place in their business or supply chains;
• The number of staff trained on our Anti-Slavery Policy and Whistleblowing Policy;
• The number of risk assessments conducted internally and within our supply chain, with the outcomes and next steps reported to Macdonald Hotels’ Board of Directors; and
• Assessment of the remedial action taken following non-compliances found during audits.

FUTURE STEPS

Macdonald Hotels believes in increased transparency in businesses’ response to the prevention of slavery and human trafficking. We will continue to monitor the effectiveness of our compliance programme and take necessary steps to promptly address any concerns or instances of slavery and human trafficking on an ongoing basis, as well as proactively making improvements to our compliance programme, and regularly risk assessing our business operations.

We will publish an updated Statement in each financial year.

Any queries in relation to this Statement should be directed to Macdonald Hotels’ Legal Department as follows:

Macdonald Hotels Limited
Macdonald Crutherland House Hotel & Spa
Strathaven Road
East Kilbride
G75 0QJ
Email: legal@macdonald-hotels.co.uk.

This Statement was approved by Hugh Gillies on behalf of Macdonald Hotels Limited on 31 January 2025.