Modern Slavery Policy

1. What is Modern Slavery?

Also referred to as ‘slavery’, ‘child labour’ and/or ‘human-trafficking’, modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another, in order to exploit them for personal or commercial gain.

2. Policy Statement

As a business with a turnover of less than £36m, Visit Kent Limited and Go To Places Limited (‘the Group’ or ‘the organisation’) is not required to publish a statement. However the organisation would like to make it known that it has a zero-tolerance approach to modern slavery and will never engage in these heinous activities. The organisation will condemn others who engage in such activities, and will not knowingly engage with anyone or any business who does so.

3. About this policy

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, suppliers and business partners.

Failure to comply with this policy may result in disciplinary action, including dismissal or termination of your contract with the Group. It could also involve other legal steps being taken against you.

This policy is not part of any employment contract. This policy may be amended at any time.

4. Personnel Responsible for this Policy

The Visit Kent Board of Directors (the ‘Board’) has overall responsibility for the effective operation of this policy and for ensuring compliance with legislation. The Board has delegated day to day responsibility for operating the policy and ensuring its maintenance and review to the Head of Operations. All employees, workers and consultants are expected to be committed to the aims of this policy.

5. Prevention of Prohibited Activities

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 and with the Group. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

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The Group ensures that the appropriate checks are made on all employees, to be certain who is working for, or on behalf of, the organisation and that they are permitted to work and paid fully and fairly for what they do.

All our employees are paid fairly according to legal requirements, the arrangements for which are properly and lawfully set out in their written contracts of employment.

The health and safety of all of our employees and workers is also of paramount importance to the Group, and we take our legal obligations very seriously, including in relation to working hours, rest breaks, and holidays.

6. Reporting Conflicts of this Policy

You must notify the Head of Operations as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur, in any of our business activities or supply chains, in the future.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, please discuss this with a member of the senior team.

The Head of Operations will take any report made to them very seriously and will promptly and responsibly investigate the allegations made or suspicions shared. They will make recommendations to and agree with our Board on the actions that should be taken following any such investigation.

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 as a result of reporting in good faith their suspicion that modern slavery of whatever form is, or may be, taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

If you believe that you have suffered any such treatment, you should inform the Head of Operations immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our grievance procedure, which can be found set out in our Grievance Policy.

7. Stakeholders and Suppliers

We expect all of our stakeholders and suppliers to share a similarly uncompromising commitment to the same levels of compliance as we have set out in this policy.

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We take a risk-based approach to our contracting processes and where appropriate may write to suppliers requiring them to comply with this policy, which sets out the minimum standards required to combat modern slavery and trafficking.

Consistent with our risk-based approach we may also require suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the policy.

As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our policy.

If we discover that any business or individual associated in any way with our business is engaged in, or otherwise supporting, and/or condoning or failing to prevent such activities, when such activities are within their control and/or influence, we will cease all connection with them. We will also consider whether we are under any reporting or other legal duty in respect of this disassociation and our reasons for it.

8. Policy Review

This policy will be reviewed on a regular basis to ensure compliance with legislation and to identify any further opportunities to help eradicate modern slavery.

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