Modern Slavery and Human Trafficking Statement 2024 for CAP Worldwide Limited
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps we have taken to minimise the risk of modern slavery in our business and supply chains.
Introduction
Modern slavery encompasses slavery, forced and compulsory labour, and human trafficking whereby individuals are deprived of their freedom and are exploited for commercial or personal gain as enacted in the Modern Slavery Act 2015 ('the Act').
CAP Worldwide is committed to a zero-tolerance approach to modern slavery and to acting with integrity in all its dealings, relationships, and supply chains. It expects the same high standards from all its staff, brand partners, suppliers, contractors, and those with whom it does business.
This commitment is evident through our company policies, which aim to uphold the highest ethical and professional standards. We ensure the adherence to policy commitments and compliance of current Government legislation and regulations.
Our organisational structure and operations
CAP Worldwide is a global serviced accommodation booking agency, providing extended- stay accommodation to corporate travellers for stays of 5 nights+ worldwide.
We operate a tri-regional service delivery model, with operations in EMEA, APAC (Singapore) and the United States, with the majority of our team members being home workers.
CAP works with a network of brand partners to provide accommodation in aparthotels, serviced apartments, corporate housing, extended-stay and short-term rental properties globally.
Our commitment to the principles of the Modern Slavery Act 2015
CAP Worldwide is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking.
As an equal opportunities employer, we are committed to creating and ensuring a non- discriminatory and respectful working environment for our staff. We want all our staff to feel confident that they can expose wrongdoing without any risk to themselves and as such the company has an established whistleblowing policy which all staff can access alongside all other company policies through the Employee Handbook on the company sharepoint site.
Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK, and where applicable subject to DBS checks in order to safeguard employees and apprentices from any abuse or coercion.
We do not enter into business or partnership with any organisation, in the UK or overseas, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.
Policies relating to slavery and human trafficking
Our key policies and procedures which contribute to minimising the risk of modern slavery and human trafficking in our organisation and within our supply chain include our:
- Health and Safety Policy
- Whistleblowing policy – which provides guidance on how to report suspected dangers or wrongdoing in the workplace including concerns regarding modern slavery and human trafficking.
- Code of Conduct Policy - our employee handbook explains the manner in which we behave as a business
- Brand Partner Agreement
All CAP Worldwide brand partners are required to agree to the terms of our Brand Partner Agreement, which sets out the minimum standards we expect from our partners.
Section 12 of the CAP Brand Partner Agreement explains that CAP will only work with Brand Partners who are compliant with, and can demonstrate compliance with on request, best practice and local laws with regard to Modern Slavery.
Our policies will be reviewed on an annual basis.
Risk Assessment
We acknowledge the risk that a supply chain may involve the use of a hidden or unknown subcontractor reliant on forced labour.
Although we consider the risk of modern slavery to be low due to the nature of our supply chains, we take our responsibilities to combat modern slavery seriously as demonstrated by the adoption of the following measures:
- The prevention, detection, and reporting of modern slavery in any part of its business or supply chains is the responsibility of all those working for CAP Worldwide or under its control.
- Appropriate due diligence processes must be carried out in relation to modern slavery which may include considering human rights in a sector or country, the type of sector in which a service provider operates, the countries from which services are provided, the nature of relationships with suppliers, and the complexity of supply chain(s).
- All supply chain lines must be continually risk assessed and managed in relation to modern slavery and any high-risk suppliers audited.
Previous actions
CAP Worldwide introduced an anti-slavery policy to all our staff following consultation, and this was incorporated within our Employee Handbook.
Our brand partner agreement was updated to reflect best practice around preventing modern slavery in our global supply chain.
Current actions
We aim to take the following further steps over the course of the next financial year ending December 2024:
Sample audit a number of smaller suppliers based on risk identification to ensure adherence to the Modern Slavery Act.
Run refresher training to ensure that relevant staff managing our global suppliers and brand partners are up to speed with the latest best practice regarding modern slavery, and embed as necessary as part of the onboarding processes.
This statement has been approved by Andrew Hopgood, Chief Operating Officer, for the financial year ending 31 December 2023.
This statement will be reviewed and updated every year.