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, G 3120 Collins Topco Limited, G 3120 Collins Holdco Limited, Generator US Opco Topco Limited, Queensgate Generator FinCo Limited, Queensgate Generator LP GP Limited, Queensgate Generator LP 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 2024.
We, through the Global Group, currently operate 21 properties across Europe and the United States and have approximately 800 employees. Generator Hostels Limited is the 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. 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.
- Agency workers policy: We use only specified, reputable employment agencies or verified personal connections 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
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and supply chains, and to embed a culture of vigilance and ethical conduct, we are committed to providing comprehensive, ongoing training and clear communication to staff.
We have implemented a structured training programme on modern slavery and human trafficking. This training is mandatory and is delivery via e-learning module, as part of the on-boarding process. Training effectiveness is periodically reviewed through completion rates. Refresher training will be provided annually or when there are significant changes to legislation, our operations, or identified risks.
The staff training covers:
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Defining modern slavery and its various forms.
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Understanding the specific risks of modern slavery relevant to Generator’s operations and supply chains.
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How to identify potential signs of exploitation and modern slavery among colleagues, contractors, suppliers, or within our premises/operations.
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Details of our zero-tolerance policy and the company’s commitment to eradicating modern slavery.
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Clear procedures for reporting concerns, including access to confidential reporting mechanisms, ensuring that individuals feel safe and supported when raising concerns.
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The importance of supply chain due diligence and ethical sourcing.
We foster an open culture where employees feel comfortable raising concerns about potential modern slavery risks without fear of retaliation. Information regarding our modern slavery policy and reporting mechanisms is readily accessible to all employees through staff handbooks and our e-learning portal.
Leadership will actively champion our anti-modern slavery stance, reinforcing the importance of this issue through internal communication and leading by example.
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.
Download the Moden Slavery Statement
here