Modern Slavery Statement
We recognise that although slavery, servitude, forced labour and human trafficking (modern slavery), is illegal it remains a growing issue in the UK. In an increasingly global marketplace, we also recognise that all businesses have a responsibility to understand whether modern slavery and human trafficking is taking place within their businesses and supply chains and this is a responsibility that we take seriously.
Definitions
Modern Slavery - the exploitation of other people for personal or commercial gain including the trafficking of people, forced labour, servitude and slavery. Children (those aged under 18) are coerced victims of trafficking, whether or not they have been coerced, deceived or paid to secure their compliance. They need only have been recruited, transported , received or harboured for the purpose of exploitation.
Human Trafficking - the movement of people by force, threat, deception or exploitation into a through a country.
We are committed to making meaningful and long-term improvements to workers’ employment and workplace conditions including but not limited to the prevention of forced, bonded and trafficked labour. We do this through our policies and governance, which are supported by a committed organisation and our leadership. We also recognise that the hospitality industry can be at a higher risk of exposure to modern slavery for the following reasons:
- Higher level of staff from overseas
- Having a transient workforce
- Having a diverse supply chain
We employ the majority of our workforce directly, however, we have a small number of independent agents that work for Barons Eden. These independent agents can complete tasks such as building works, Personal Training or Consultation Services. All independent agents are contracted directly.
Barons Eden undertakes the following due diligence processes in order to determine whether or not their activities or countries of operation may be considered of high risk in relation to modern slavery or human trafficking:
- Assessment of suppliers and partners, and application of their Supplier Code of Conduct.
Responsibilities
Barons Eden has assigned the following key responsibilities:
- Policies: led by the HR team and updated annually.
- Staff training: all employees are made aware of this statement and given guidance on how to recognise and raise the alert regarding modern slavery and human trafficking risks.
Supply Chain
We procure goods and services from a number of UK based suppliers in areas such as; Furniture, fixtures and fittings, Food and Beverage and Operational Supplies.
We have contractual relationships with all of our suppliers and a dedicated Procurement team to oversee the instruction of supplier agreements and ensure that adequate procedures are in place.
Supply Chain Due Diligence: led by our procurement team and carried out for all major suppliers and partners.
Supply Chain Due Diligence
Barons Eden undertakes due diligence when considering new suppliers and regularly reviews their existing suppliers. Barons Eden’s supplier due diligence process involves:
- Distributing our Supplier Code of Conduct to all suppliers.
- Conducting supplier screening processes that includes asking suppliers for their ESG credentials.
- Invoking sanctions or terminating partnerships with suppliers who fail to improve their performance.
RISK AND MONITORING COMPLIANCE
We shall continue to monitor our new supplier risk for any suppliers that fall within an area that is at high risk of modern slavery. We shall continue to address modern slavery with these suppliers by requesting copies of their policies and procedures and carry out our own audits. We have also included new learning modules for all of our teams on Modern Slavery and provide all management with a recruitment training course to attend to ensure strict compliance.
Barons Eden have acknowledged that it is their duty to prevent modern slavery and human trafficking in all areas of their operations and supply chains.
Overview
This policy applies to all Barons Eden employees and contractors. It also applies, as far as is reasonably achievable, to our upstream and downstream supply chain through partners, suppliers and third-party contractors.
Our Commitment to Human Rights
Barons Eden is committed to upholding human rights throughout our operations and supply chain. Barons Eden recognises our responsibility to respect and protect the human rights of all individuals, including our employees, customers, suppliers, and the communities in which we operate.
This policy outlines our commitment to
Compliance with National Law and International Human Rights Standards: Barons Eden will comply with all applicable laws and regulations related to human rights, including those in the UK and any other jurisdictions where we operate. Where national law and international human rights standards differ, the higher standard will be followed; where we are in conflict, national law will be adhered to, while seeking ways to respect international human rights to the greatest extent possible.
Respect for International Human Rights Standards: Barons Eden will respect internationally recognised human rights and principles, as set out in the:
- International Bill of Human Rights (consisting of the Universal Declaration of Human Rights (UDHR), International Covenant on Economic, Social and Cultural Rights and International Covenant on Civil and Political Rights.
- International Labour Organisation’s (ILO) Declaration on Fundamental Principles and Rights at Work.
- The United Nations Guiding Principles on Business and Human Rights.
Due Diligence: Barons Eden will conduct ongoing due diligence to identify, assess and manage potential human rights risks associated with our operations and supply chain. Potential human rights risks are overseen by the Board of Directors.
Grievance Procedures and Transparency: Barons Eden have an appropriate grievance mechanism in place for any identified human rights issues and will be transparent about human rights practices and performance.
Barons Eden does the following:
- Work with Employment Lawyers
- Work with the leadership team on human rights
- Work with supply chain partners
- Work with the senior management team and HR department to ensure the implementation and regular review of robust, transparent policies that advance human rights, positively contribute to their promotion, and meet legal human rights requirements.
Stakeholder and Supply Chain Relationships
Barons Eden expects that our employees, business associates, and any other entities whose actions may have a direct connection to our operations will uphold human rights standards.
Barons Eden will:
- Communicate Expectations: Clearly communicate our human rights expectations to suppliers and other stakeholders, through our Supplier Code of Conduct.
- Monitor Performance: Where appropriate, monitor supplier performance and take action to address any concerns.
- Support Improvement: Support supplier efforts to improve our human rights practices.
Employment Practices
Barons Eden is committed to providing a safe, fair and respectful workplace for all employees.
- Equal Opportunity: Providing equal opportunities for all employees.
- Fair Treatment: Ensuring fair wages, working conditions and treatment of all employees. All employees receive salary reviews.
Anti-Harassment: Prohibiting discrimination and harassment.
- Health and Safety: Providing a safe and healthy working environment and complying with all relevant health and safety laws and regulations. We have a Company Health and Safety Policy that employees are required to read and sign.
- Respecting Rights: Respecting employee rights to freedom of association.
- Anti-Slavery: Preventing and eliminating all forms of modern slavery, forced labour and child labour practices. Our Modern Slavery Statement can be found on the Barons Eden website.
Transparency and Communication
Barons Eden recognises the importance of transparency and communication regarding human rights Barons Eden will:
- Stakeholder Engagement: Engage with stakeholders, including employees, suppliers, and communities, to gather feedback and address concerns.
- Employees receive access to policies via Harri, a Learning Management System (LMS). Employee engagement with the resources on the platform is tracked to ensure that everyone has read and understood each company policy. Policies are regularly updated by HR, as necessary, and will be signed off by members of the leadership team.
- All suppliers receive a copy of our Supplier Code of Conduct that is reviewed and updated, when necessary. All new suppliers undergo a robust screening process to ensure that we are engaging in ethical practices.
- Reporting: Report on our human rights performance, including any challenges and progress made through annual impact report.
- Training: Provide training to employees on human rights issues and our responsibilities.
- Barons Eden provides all leadership positions with training. The company holds strategy days that discuss new policies or revise existing policies. Conflict resolution and management training occurs once every quarter.
- All employees, via Harri, must undergo onboarding and annual training and awareness programmes. This platform ensures that training and awareness session completion rates are measured and employee training is kept up to date.
Grievance Mechanism
Barons Eden has a grievance mechanism to allow employees, contractors, and other stakeholders to raise human rights concerns. All complaints will be investigated promptly and fairly. Please see Grievance Policy.
Barons Eden Group has a Designated Safeguarding Lead (DSL) to whom employees can also report grievances to. Each location as a Safeguarding Officer.
At Barons Eden we are committed to conducting business in an ethical, transparent, and responsible manner. We expect our suppliers to adhere to the highest standards of integrity, sustainability, and fairness. This Supplier Code of Conduct outlines the principles and standards we require our suppliers to uphold to ensure we work together in an ethical and socially responsible manner.
Compliance with Laws and Regulations
We expect our suppliers to abide by all applicable laws and regulations in any jurisdictions in which they operate.
1. Ethical Business Practices
Honesty and Integrity: Suppliers must conduct their business with the highest level of honesty and integrity, ensuring that all interactions and transactions are transparent, fair, and free from bribery, corruption, or unethical practices.
Anti-bribery and Corruption: Suppliers are expected to comply with all applicable anti-bribery and anti-corruption laws, ensuring that no form of bribery, kickbacks, or improper influence is accepted or offered.
Conflicts of Interest: Suppliers should avoid any conflict of interest in their business dealings and disclose any situation where a conflict may arise.
2. Labour and Human Rights
Fair Labour Practices: Suppliers must adhere to all applicable laws regarding working hours, wages, and conditions of employment. No employee should be required to work beyond their legal limits or be paid less than the national minimum wage.
Non-Discrimination: Suppliers should provide a work environment free from discrimination based on race, gender, age, religion, disability, sexual orientation, or any other status protected by law.
Child and Forced Labour: Suppliers must ensure that their operations are free from child labour and forced or compulsory labour. All employees should be hired freely, with their consent and without coercion.
Freedom of Association: Suppliers should respect the right of employees to freely associate, join trade unions, and collectively bargain where applicable, without fear of retaliation.
3. Health and Safety
Safe Working Conditions: Suppliers must provide a safe and healthy work environment for their employees. They should identify and mitigate any health or safety risks, ensuring compliance with relevant health and safety legislation.
Well-being: Suppliers are encouraged to offer health and well-being programmes and promote the mental and physical well-being of their workers.
4. Environmental Responsibility
Environmental Impact: Suppliers must strive to reduce their environmental impact and adopt sustainable practices in their operations. This includes efforts to reduce waste, conserve energy, reduce emissions, and manage resources efficiently within their direct control.
Compliance with Environmental Laws: Suppliers must comply with all applicable environmental laws and regulations in the countries where they operate, including those related to waste disposal, emissions, and the use of hazardous substances.
5. Fair Trading and Transparency
Supply Chain Transparency: Suppliers should ensure transparency in their supply chains and be able to provide information regarding their sourcing practices, including the origin of raw materials.
Accountability: Suppliers should be accountable for their actions and provide the necessary documentation to demonstrate compliance with the requirements outlined in this Code of Conduct.
Anti-Competitive Practices: Suppliers should avoid engaging in anti-competitive practices, including price fixing or market manipulation, and comply with relevant competition laws.
6. Data Privacy and Confidentiality
Protection of Personal Data: Suppliers must protect the personal data of employees, customers, and any other individuals involved in their operations. This includes complying with data protection laws, such as the UK’s Data Protection Act and GDPR.
Confidentiality: Suppliers must maintain the confidentiality of any proprietary or sensitive information provided by [Your Company Name] and not disclose or use such information for any unauthorised purpose.
7. Compliance with Laws and Regulations
Legal Compliance: Suppliers must comply with all applicable local, national, and international laws, regulations, and industry standards. This includes compliance with laws relating to employment, environmental protection, health and safety, and business ethics.
Audit and Monitoring: Suppliers agree to allow Barons Eden or a third-party auditor to conduct reasonable audits and inspections to ensure compliance with the terms of this Code of Conduct.
8. Business Integrity
Respect for Intellectual Property: Suppliers must respect intellectual property rights and refrain from infringing on patents, trademarks, copyrights, and other intellectual property laws.
Responsible Sourcing: Suppliers are expected to adopt responsible sourcing practices, ensuring that raw materials are obtained ethically and that suppliers themselves adhere to fair practices.
9. Continuous Improvement
Ongoing Development: Suppliers should continually work to improve their business practices, implementing improvements related to ethical conduct, labour standards, environmental sustainability, and health and safety.
Collaboration and Feedback:
Suppliers are encouraged to engage in dialogue with Barons Eden to enhance and develop mutually beneficial relationships that promote shared values and goals.
Acknowledgement and Compliance
By entering into a business relationship with Barons Eden suppliers agree to adhere to this Supplier Code of Conduct and to uphold the principles set forth herein. Any violation of these standards may result in the termination of the business relationship.
About Barons Eden
Barons Eden is a collection of award-winning spa and hotel destinations, dedicated to relaxation, social connection, and sustainability. As a leader in sustainable hospitality, we embrace our responsibility to minimise environmental impact, for our planet, our people, and our guests. At Barons Eden, sustainability is woven into every experience, ensuring a future that is both luxurious and responsible.
Committed to achieving the highest sustainability standards, our values align with the UN’s Sustainable Development Goals and are committed to carbon neutrality by 2050. At Barons Eden, our dedication to sustainability goes beyond environmental responsibility. We are committed to upholding the highest ethical standards, ensuring we don’t just meet legal requirements but consistently exceed them in every region we operate.
About this Code
Barons Eden strives to maintain the highest levels of ethical conduct across all aspects of our business. This Code outlines our core principles and best practices, guiding our commitment to honesty, integrity, and professionalism in our actions and decision-making.
Fairness
Barons Eden is committed to fairness and equity in all its business dealings. We will always act with honesty and transparency and expect the same from our partners and suppliers.
Individual Responsibility and Accountability
At Barons Eden, we value individual responsibility and accountability. We empower all employees, board members, and contractors to work freely without undue restriction or sanction, while holding ourselves to the highest ethical and professional standards. We expect the same from everyone associated with Barons Eden.
Environmental Responsibility and Accountability
Barons Eden is committed to reducing its negative environmental footprint. We continuously strive to lower greenhouse gas emissions from both our operations, and those of our partners and suppliers.
We encourage all employees to consider their environmental impact by being mindful of material and energy use in the workplace, seeking opportunities to conserve, recycle, reduce, or reuse resources.
For further information on how we enact our environmental responsibility, please refer to our ESG Statement.
Compliance with Applicable Laws and Regulations
Barons Eden adheres to all applicable laws and ethical standards in every territory where we operate. In cases where the ethical standards in one jurisdiction surpass those in another, Barons Eden applies the higher standards consistently across all regions, ensuring integrity and fairness in every practice.
Conflicts of Interest
Barons Eden is committed to maintaining transparency and integrity in all business relationships. We require employees, partners, and suppliers to disclose any actual or potential conflicts of interest that may compromise impartiality or create a clash between personal, financial, or professional interests and the interests of Barons Eden.
Common conflicts include:
- Holding external employment or directorships that may affect impartiality.
- Having financial or personal ties to Barons Eden’s suppliers, vendors, or customers.
- Engaging in business dealings with close personal connections.
We require employees to submit Declaration of Conflict of Interest forms (GPAI-HR-F002), with high-risk roles completing this annually. Partners and suppliers must also disclose any conflicts within their organisations. Failure to disclose conflicts may raise concerns over fairness, compliance, and ethical conduct.
Equity, Equality, and Parity
Barons Eden strives for equity and equality within its own operations, ensuring diversity and inclusion across our workforce and trustees. We actively assess diversity at all levels and integrate these considerations into all employment practices. We expect our partners to uphold these same principles.
Financial Reporting
Barons Eden maintains a policy of financial transparency and expects the same from all its suppliers and partners.
Reporting Violations and Protection from Retaliation
Barons Eden operates a whistleblowing programme that allows all employees and associates to report breaches or violations of our Code of Ethics. We ensure there will be no discrimination or retaliation against anyone who reports a violation in good faith. Please refer to our Whistleblowing Policy, which can be found in our Employee Handbook.
Social Impact
Barons Eden is committed to having a positive social impact in all the territories where we operate. We fulfil this pledge by actively supporting local communities, promoting sustainable practices, and ensuring that our operations contribute to the overall well-being of society.