Modern Slavery Act
Modern Slavery Act Transparency Statement
This statement (the “Statement”) is made pursuant to s.54(1) of the Modern Slavery Act 2015 by Queensgate Bow Holdco S.à r.l. which is incorporated in Luxembourg (the "Company").
The Company acknowledges the provisions of the Modern Slavery Act 2015 (the “Act”). The Act creates offences in respect of slavery, servitude, forced or compulsory labour and human trafficking (“Modern Slavery”). The Company and the Group (as defined below), are committed to combatting all forms of Modern Slavery.
The Company is the direct or indirect parent of Queensgate Bow Propco Limited, Queensgate Bow Opco Limited (the “Opco”), Queensgate Bow UK Holdco Limited, Queensgate Bow UK Midco Limited, Queensgate Bow UK Topco Limited, and Queensgate Bow UK Parent Limited (together, the “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 2020 (the “Financial Year”).
Group business and supply chain
The Company, through the Group, carries out business as a hotel located in Central London (in respect of the Holiday Inn Kensington Forum (the "Hotel")) and Opco engages Queensgate Hospitality Management Limited (“QHML”) to manage the Hotel. Within the provisions of accommodation, conference and events and food and beverage services, Opco employs up to 138 staff directly and has relationships with external businesses to support the running of the Hotel in the following way:
- Arrangements for the supply of goods and services (some by contractors) to the Hotel.
- Arrangements with QHML to manage the hotel property on behalf of Opco and the supply of agency workers to support the Hotel's staffing requirements.
Due diligence processes
As part of Opco's due diligence process in the Financial Year, Opco has engaged QHML to:
- Advise on and identify the areas within its business and supply chain which may be at risk of modern slavery, human trafficking, child and sexual exploitation occurring.
- Advise on any new or renewed contracts for service/supply within the supply chain which may need to guarantee slavery, human trafficking, child and sexual exploitation does not occur with their business, and incorporate provisions to review/audit those suppliers where necessary.
QHML has also been engaged to advise Opco on training which may be required to educate its employees on the potential risks and how to deal with them (if they were to arise) as a way of limiting and preventing those risks from occurring. This included any regular agency workers (from the supply chain) who work in the identified areas of risk within those businesses.
The Company, Opco (advised by QHML) and the other companies forming part of the Group will not knowingly support or deal with any business involved in slavery, human trafficking, child or sexual exploitation.
This statement has been approved by the board of directors of the Company and the board of directors of Opco and is signed by all the managers of the Company.