Modern Slavery Statement

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015. This is easyHotel’s first statement and it constitutes easyHotel’s anti-slavery and human trafficking statement for the financial year ending 31 December 2022.

Introduction

At easyHotel we are committed to preventing acts of modern slavery and human trafficking from occurring within our business and supply chain, and we impose the same high standards on our suppliers. We are committed to ensuring that there is transparency in our business and in our approach to preventing modern slavery in our supply chain.

Our business structure and supply chain

easyHotel is an international hospitality company which owns, operates, develops and franchises low-carbon hotels under the ‘easyHotel’ brand. We are present in 30 cities and have an estate of 44 hotels, 26 hotels are owned, and 18 hotels are franchised. In order to provide affordable accommodation in an ecologically responsible manner, we work with a range of suppliers who broadly fall into two categories: hotel suppliers and support suppliers. Our hotel suppliers provide all goods and services used in the operation of the hotels and our support suppliers provide all ancillary services and goods required by our support office team. Procurement of suppliers is managed by internal stakeholders within our support office team, they choose our suppliers carefully in accordance with the below-mentioned policies

Policies

As part of our commitment to combating modern slavery, we have implemented an anti-slavery policy and amended our supplier management policy. We also make sure our suppliers are aware of our anti-slavery policy and adhere to the same high standards. implement right-to-work checks on all new employees in accordance with our recruitment and selection policy. Our whistleblowing policy also supports with the prevention of modern slavery. 

Due diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have implement internal audits for our suppliers and franchisees. Our suppliers and franchisees are aware of our zero-tolerance approach to slavery and human trafficking. Our procedures are designed to:

• establish and assess areas of potential risk in our business and supply chains

• monitor potential risk areas in our business and supply chains

• reduce the risk of slavery and human trafficking occurring in our business and supply chains

• provide adequate protection for whistleblowers  

Risk and compliance

easyHotel periodically evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain. We consider easyhotel to have a moderate risk because we operate in a labour-intensive industry. Where we identify a potential risk, we will investigate such risk and take appropriate action. We ensure all our suppliers adhere to our anti-slavery policy. We do not tolerate slavery and human trafficking within our supply chains. If we find evidence of a failure to comply with our anti-slavery policy, we have provisions in our contracts that allow us to immediately terminate the contract.

Key performance indicators (KPI) and effectiveness

We do not have specific KPI reporting. However, following our review of our actions this financial year, we have the following objectives and action steps:

Objective: Ensure all new and existing suppliers are aware of, and comply with, our modern slavery policy. 

Action Step: Send all new suppliers a copy of our anti-slavery policy, before we enter into any contract and require them to adhere to it. Send all existing suppliers a copy of our anti-slavery policy. Suppliers considered high risk will be asked to confirm adherence with the policy.

Objective: Ensure that our supplier management practices and modern slavery policy are adequately addressing the modern slavery risks we face. 

Action Step: Undertake an annual review of our modern slavery policy and procedures to ensure they remain fit-for-purpose for identifying, mitigating and remediating identified and potential risks of modern slavery in our supply chains.

Objective: Ensure we have contractual recourse under standard supply contracts if modern slavery issues are subsequently identified.

Action Step: Incorporate our standard anti-slavery contractual wording in all new contracts. Where an agreement, with a supplier operating in a high-risk sector or location, does not provide adequate recourse where modern slavery issues are identified, amend standard supply contract wording by 31 December 2025 to include warranties on modern slavery compliance, termination rights for non-compliance and audit rights.

Objective: Ensure that all staff are aware of the risks associated with modern slavery that we face as a Group, and ensure those in relevant roles review the modern slavery risk management strategy at least annually

Action Step: Ensure all employees in the easyHotel Group undertake modern slavery awareness training at least annually. 

Action Step: Complete an annual internal review of our modern slavery risk management strategy and supplier management practices with operations, front-line procurement and other relevant staff. 

Training and awareness

We invest in educating our staff to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our training, employees are encouraged to identify and report any potential breaches of our anti-slavery and human trafficking policy, and report any concerns they may have about guests, colleagues, someone in our supply chain or someone unrelated to easyHotel. Anti-slavery training is mandatory and completed on an annual basis. In team areas at our hotels, we display posters that detail key signs that could indicate that someone may be a slavery or trafficking victim and how an employee should report a suspicion.

Our on-going commitment

As a responsible business, we recognise the importance of continual improvement and developing our approach to combating modern slavery and human trafficking. We will review our approach and objectives at least annually.

Approved by the Board of Directors of easyHotel Limited on 19 April 2023. 

Karim Malak

Chief Executive Officer