ABOUT ATLAS HOTELS GROUP

Atlas Hotels Group is the parent company of the individual companies that own and/or operate 58 hotels across the UK, employing in excess of 1,000 employees.

We believe we have a responsibility to manage our business to positively impact those we interact with. This statement sets out the steps taken, and those that Atlas Hotels Group intends to take in the future, to prevent modern slavery and human trafficking in our supply chains or in any part of our business.

This statement is published in line with the Modern Slavery Act 2015 (“MSA”).

SUPPLY CHAIN

Our supply chain includes suppliers of goods and services, almost exclusively based in the UK with our labour force comprising employees and temporary workers when required.

POLICIES ON SLAVERY AND HUMAN TRAFFICKING

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. This statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain.

RISK ASSESSMENT, PREVENTION, MITIGATION

As part of our initiative to identify and mitigate risk, we assess potential risk areas in our supply chain through:

• Risk reviewing suppliers based on spend, location and type of product or service provided
• Risk assessing suppliers on size and type of organisation ranging from large corporates to small independents
• Encourage reporting of concerns through our Whistleblowing Policies
• Audit suppliers’ compliance with MSA 2015 by requesting copies of their MSA statement

TRAINING

To ensure a high level of understanding of modern slavery and human trafficking risks in our supply chain and business, we provide annual training to our staff.

MONITORING EFFECTIVENESS IN COMBATTING MODERN SLAVERY

We will measure the effectiveness of our policy through:

• Audits of our supply chain and supplier contracts
• Annual risk assessments
• Monitor compliance with MSA 2015 training

FURTHER STEPS

Further areas for development have been identified as:

• Develop a formal Anti-Slavery Policy
• Ensuring anti-slavery clauses are contained within all key supplier contracts, inclusive of contract novated through any asset acquisitions
• Continuing to review our training programme compliance

Atlas Hotels Modern Slavery policy 2023 has been approved by the Board of Directors.