Anti-slavery and Human Trafficking Code of Conduct

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.

Interstate  Hotels  & Resorts (who manage Jupiter Hotels)  has  a  zero-tolerance  approach  to  slavery  and  is  committed  to  acting  ethically  and  with  integrity  in  all  business  relationships  and  to  ensuring  there  are  no  acts  of  slavery  within  any  parts  of  our  business  or  supply  chains.

The Company and its employees undertake to comply with the principles of all  legislation  in  relation  to  modern  slavery.  We  expect  all  third  parties  that  we  do  business with to maintain the same high standards and this Code of Conduct applies to  all  Directors,  employees,  agency  workers,  contractors,  consultants,  third  party  representatives and business partners.

Our  systems  and  controls  seek  to  ensure  that  modern  slavery  is  not  taking  place  either within our own business or in any of our supply chains.  We will not enter into business  with  any  third-party  making  use  of  forced,  compulsory  or  trafficked  labour  or anyone held in slavery or servitude (whether adults or children) nor do we tolerate such activity within our own business.

We will introduce obligations on our supply chain both before signing contracts with a third party and on an ongoing basis for the duration of any contract.

The  Board  of  Directors  has  overall  responsibility  for  the  Code  of  Conduct  and  for  ensuring that those under our control comply with both our Code of Conduct and the Act.

Under our Code of Conduct, employees and anyone doing business with the Company are expected to:

1. Comply  with  the  provisions  of  all  legislation  related  to  modern  slavery  (e.g.  the Modern Slavery Act – MSA) and of this Code of Conduct;
2. Avoid any activity resulting in a breach of the requirements of the MSA or this Code of Conduct;
3. Raise any concerns about any suspicion of modern slavery in any part of our business or supply chains;
4. Prevent,  detect  or  report  any  instances  of  modern  slavery  within  our  business  or  supply chains.

Reporting should be to one of the following:

• Line manager (for employees); or
• Interstate Hotels Managing Director; or
• Principal Interstate contact (for third parties);
• Modern Slavery Helpline on 0800 0121 7005

Raise  concerns  immediately  if  there  is  a  suspicion  of  a  breach  of  the  Code  of  Conduct. If  any  employee  breaches  this  Code  of  Conduct,  they  will  face  disciplinary  action  which may result in dismissal for misconduct.

If  any  third  party  that  we  do  business  with  breaches  this  Code  of  Conduct,  where  practicable  and  subject  to  the  terms  of  their  contract  with  us, we will terminate our relationship with them.

Environmental Commitment

As a leading hotel operator in the UK, Jupiter Hotels Ltd recognises that our operations have an effect on the local, regional and countywide environment.

As a consequence of this, the management are committed to continuous improvements in environmental performance and the prevention of pollution. Environmental regulations, laws and codes of practice will be regarded as setting the minimum standards of environmental performance.

The Chief Executive is responsible to the Board for the company’s performance and implementation of this policy. The Chief Executive will be supported by a nominated member of the Executive Team who will provide regular reports on progress.

Overview of the Strategy and Action Plan

1. A ‘Steering Group’ has been set up to lead activity on a range of objectives. The steering group will develop and maintain activity on the action plan. The objectives and action plan will be communicated to all employees.
2. The Green Tourism Business Scheme (audit and grading ) has been established as the key framework for assessing performance and monitoring improvements. Employees and suppliers will be directly impacted and our customers will be encouraged to support initiatives.
3. The main focus is on reducing consumption and improving efficiency in our Energy and Waste Management processes. Targets for each business are set for reducing energy, waste and water consumption. These targets are treated as Key Performance Indicators when reviewing local management performance.

Our approach is guided by a number of principles which all employees (hotel and support centre) are required to support.

Principles

1. 1. 1. Senior management sets out the responsibility for environmental performance and develops and maintains an adequate system of management, measurement and improvement.
      2. All actions comply with relevant regulations.
      3. The business operations are regularly assessed for compliance with policy, performance and achievement of targets.
      4. Employees are encouraged to work in an environmentally responsible manner.
      5. Suppliers are encouraged to operate in an environmentally responsible manner.
      6. Where appropriate, we will encourage support from customers by providing them with products and services that are environmentally responsible in use.
      7. Customers are made aware of all environmental policies in the specific areas where they are in direct contact.
      8. The company discusses and reviews action plan progress and performance against targets on a regular basis across all levels of the organisation.

    

   Key Elements

    

   Management System / Communication

   1. 1. 1. 1. • Activity is lead by a Steering Group – 6 employees representing all levels of business management.
               • The Steering Group meet regularly to discuss implementation of new initiatives, and the delivery of hotel based activity aimed at achieving targeted improvements.
               • GTBS Audit and Grading Scheme is used as a basis for setting improvement targets, and measuring progress across all areas covered by the policy. League tables will be published showing individual hotel scores with each hotel responsible for their own local action plan.
               • The company intranet is used as the principal point of communication. Employee engagement is critical to the success of this policy and the sharing of best practice and successes.
               • Performance against consumption targets is published on the front page of period management accounts. This performance will form a key part of the businesses performance management review process.

   Energy Consumption

   1. 1. 1. 1. • Mechanical and electrical maintenance contracts place a duty on the contractor to inform the company of plant operating at low efficiency, and to advise of further measures that may reduce energy consumption. Preventive maintenance contracts are in place for all major plant and critical operating equipment. Contractor performance is reviewed regularly.
               • Additional audits are conducted by external providers e.g. The Carbon Trust to identify specific opportunities to reduce consumption, improve process and measure contractor performance.
               • Electrical fittings and consumables are purchased with regard to ‘efficiency’.

   Water

   1. 1. 1. 1. • Targets will be set for the reduction of water consumption and associated waste following benchmarking exercises and the reports of specialist consultancies.
               • Improvements will be delivered through awareness programmes, flow restriction technology, excess capacity reduction and infrastructure maintenance.

   Waste Management

   1. 1. 1. 1. • Targets will be set for the reduction of our landfill waste output and for the increased use of recycling where commercially viable.
               • The use of print paper and ink will be reduced through the continued development of our IT infrastructure and improved staff awareness.

   Suppliers

   1. 1. 1. 1. • Our Pre-Qualification process for contractors ensures that we only use representatives from responsible companies to work within our organisation.
               • Suppliers are encouraged to have a valid and active environmental policy. When dealing with our suppliers we are increasingly including elements of sustainability and environmental awareness.

   Transport

   1. 1. 1. 1. • Training/meeting transport will be minimised through the ‘regionalisation’ of meetings, training delivery and the increased use of conference calls and computer based training.
               • Staff are encouraged to use public transport wherever possible.

   Culture / Awareness

   1. 1. • The Executive Team are committed to the implementation of this policy and will give full backing to all those authorised to carry it out.
         • Employee involvement in environmental matters is encouraged at all levels and will be promoted through training, communication and the on-going reappraisal of our working routines.