Modern Slavery Statement for Financial Year 2018

This statement is made pursuant to section 54 of the Modern Slavery Act 2015

Introduction
This statement (the “Statement”) is made pursuant to section 54(1) of the Modern Slavery Act 2015 by Queensgate Generator S.à. r.l. which is incorporated in Luxembourg (the “Company”).

This Statement sets out the Group’s (as defined below) 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.
As part of the hospitality industry, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.
We are committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking.

Group structure
The Company is the direct or indirect parent of Queensgate Generator Holding Limited, Generator Hostels Limited, Queensgate Generator Properties Limited, Generator Hostel London Limited, G3120 Collins Parent Limited and G 640 Main Parent Limited, which are incorporated in England and Wales and jointly represent the Company’s operations related to United Kingdom (together, the “Group”). The Company has further business and subsidiaries incorporated across the globe, which together with the Group is referred to as the “Global Group”.

The Company is making the Statement on behalf of itself and each of the companies forming part of the Group for the financial year January – December 2018.
We, through the Global Group, currently operate 14 properties across Europe and the United States and have approximately 550 employees. The Global Group had annual turnover in excess of €85 million to the end of October 2018. Generator Hostels Limited has its head office in the UK.

Our supply chains
Our supply chains include, but are not limited to, sourcing temporary staff, as well as for our own direct hospitality services.  We expect our suppliers and potential suppliers to aim for high ethical standards and to operate in an ethical, legally-compliant and professional manner by adhering to our supplier code of conduct. We also expect our suppliers to promote similar standards in their own supply chain.

Relevant policies
We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:
  • Whistleblowing policy: We encourage all workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
  • Employee code of conduct: Our code makes clear to employees the actions and behaviour expected of them. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
  • Procurement code of conduct: We are committed to ensuring that suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their workers’ working conditions. However, serious violations of our supplier code of conduct will lead to the termination of the business relationship.
  • Agency workers policy We use only specified, reputable employment agencies to source labour and always verify the practices of any new agency we are using before accepting workers from that agency.
Compliance
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. All staff are required to avoid any activity that might lead to a breach of this policy.

If staff believe or suspect a breach of or conflict with this policy has occurred or may occur, they must notify their line manager. All staff are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains as soon as possible.

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. We are 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 our business or supply chains.

Training and communication
Regular training on this policy, and on the risk that the business faces from modern slavery in supply chains, will be provided to staff as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases.

Our zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them.

Breach of the policy
Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.
We may terminate commercial relationships with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.
 
Further steps
We shall continue to review the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains.

Director approval
This statement has been approved by the Company’s Board of Directors on behalf of the Group. A new statement will be published annually.