modern-slavery and human rights policy

Policy statement

Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking. Travel Places has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity and transparency in all of our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either our own business or in any of our supply chains. This is consistent with our obligations under the Modern Slavery Act 2015.

Travel Places expects the same high standards from all of our suppliers, contractors and other business partners. As part of our contracting processes, we include specific prohibitions against the use of modern slavery and we expect that our suppliers will in turn hold their own suppliers to the same standards.

Identifying potential victims of modern slavery or human rights violation can be a challenge because the crime can manifest itself in many different ways. There is a spectrum of abuse, and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, sexual exploitation, slavery or forced labour in a work environment. In addition, some companies may go to great lengths to hide the fact that they are using slave labour. However, we accept that we have a responsibility through our due diligence processes to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.

This policy applies to all individuals working for Travel Places or on our behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.  The policy is embodied in our code of ethics, which applies to all our employees.

Responsibility for the policy

The board of directors has overall responsibility for ensuring that this policy complies with our legal and ethical obligations.

Our HR department has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible for investigating allegations of modern slavery in our business or supply chains.

All Travel Places line managers are responsible for ensuring that those reporting to them understand and comply with this policy.

Compliance

The prevention, detection and reporting of modern slavery and human rights violations in any part of our business or supply chains, whether in the UK or abroad, is the responsibility of all those working for Travel Places or under our control. Employees are required to avoid any activity that might lead to a breach of this policy.

If our staff believe or suspect a breach of or conflict with this policy has occurred or may occur, they must notify their line manager or report it to a Director immediately. Our employees are encouraged to raise concerns about any issue or suspicion of modern slavery and human rights violations in any part of our business or supply chain as soon as possible. If our employees are unsure about whether a particular act, the treatment of workers or their working conditions within any of our supply chains constitutes any of the various forms of modern slavery, they are expected to raise it with their line manager or are advised to contact the government’s Modern Slavery Helpline on 0800 0121 700 for further information and guidance on modern slavery.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. Travel places is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of our supply chains.

Statement of Commitment to Respect for Human Rights

Travel Places respects and promotes human rights and is committed to fair and equal treatment of all persons and to conducting business in an ethical manner. We treat every individual and client with dignity, fairness and respect and strive to maintain a diverse workforce and culture where differences are embraced.

Breach of the policy

Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.

Travel Places may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery or human rights violations.