modern Slavery Statement

Introduction

Established in 1996, PREM Group is an international hospitality business operating in Ireland, the United Kingdom and Continental Europe. It is the parent company to several businesses including its hospitality management division PREM Hospitality, Rate Wise (revenue management company) Sprint Digital (digital marketing agency), Trinity Hotel Groups (securing inbound tour operator business) and Premier Business Centres (serviced offices).

PREM Group currently owns 5 properties including Osprey Hotel Naas, Cahernane House Hotel Killarney, Hoban Hotel Kilkenny, Leopold Hotel Sheffield and PREMIER SUITES Dublin Leeson Street.

PREM Group in numbers

  • 34 hotel and serviced apartment properties (Including Leased, Owned and Managed)

  • Operating in Ireland, England, Scotland, Belgium, and The Netherlands

  • 1,100 employees under direct report

  • 25 years in business

  • 60 employees at the Dublin Head Office

OVERVIEW

This is PREM Group’s first statement and is made for the financial year ending 2022.

It sets out our actions to understand potential modern slavery risks related to our business and to put procedures in place that are aimed at ensuring there is no slavery or human trafficking in our businesses or supply chains. As we operate within the hospitality industry and an increasingly global marketplace, we recognise that we have a responsibility to take a robust approach.

Modern Slavery Definition

Modern slavery is an umbrella term for all forms of slavery, human trafficking and exploitation. It is a crime that affects some of the most vulnerable in society. It is often hidden from view and many victims do not self-identify. It is an international crime affecting individuals around the world. This global issue transcends age, gender and ethnicities; it is estimated that 1 in 4 victims of modern slavery are children and that 3 quarters are women and girls.

Human trafficking is defined in the UN Trafficking in Persons Protocol, which supplements the United Nations Convention against Transnational Organized Crime, as “the recruitment, transport, transfer, harbouring or receipt of a person by such means as threat or use of force or other forms of coercion, abduction, fraud or deception for the purpose of exploitation”. Although human trafficking often involves an international cross-border element, it is also possible to be a victim within your own country.

Group Policy

The Group strives to act ethically with integrity, honesty and professionalism in all aspects of our business. At PREM Group, we believe in doing the right thing always. This ethos operates on both a commercial and human level. We evolve and adapt making smart commercial decisions that are performance-driven yet we work with a higher purpose. We aspire to set industry standards. We want PREM Group to be synonymous with quality and innovation. The PREM Group principle of doing the right thing trickles down through our organisations. It means doing the right thing for our stakeholders, for our people, for our clients, for the industry we love and ultimately for our guests.

Commitment

PREM Group is committed to combatting modern slavery and human trafficking, educating team members on the issue, and encouraging our partners, stakeholders and the broader business community to take a stand against slavery and human trafficking. We operate to high standards and advocate socially and environmentally sustainable business practices. Our aim is to combat and eliminate any form of modern slavery and to operate our business without slavery, sexual exploitation, exploiting of children, or forced, bonded, or compulsory labour.

PREM Group strives to ensure that:

  • Every employee has a worker contract

  • No employee is forced to work

  • No employee is forced to handover government-issued identification, passports, work permits, or bank cards to a third party

  • No employee is required to pay any fees in exchange for work

  • No excessive deductions are made from any employee’s wages

These expectations are applied and included in the practices of the recruitment agencies and outsourced labour suppliers that we engage.

Recruitment

The vast majority of people working at our hotels and serviced apartments are employed directly by us. There are dedicated HR Managers in each property and a formal policies, procedures and approval structure is in place over recruitment. Our recruitment and employment policies are followed to ensure, as far as possible, that the business is not exposed to the fraudulent recruitment of employees and the exploitation of workers in our hotels.

We use a third-party agency for the provision of housekeeping services at our UK hotels. We recognise that this could be an area of increased risk and therefore additional focus. This arrangement operates under a formal contract which includes a “right to audit” clause.

We also use, on an ad-hoc basis, other agencies to provide us with workers for specific circumstances in our hotels, such as large events. We request a Modern Slavery and Human Trafficking policy from all providers.

Training and Induction

As part of the PREM Group induction process, specific training is used to increase awareness of modern slavery and human trafficking. It provides guidance on due diligence processes. The training includes information on responsible practices.

The following policies are embedded throughout our organisation and support the mitigation of any risk that a team member may be subject to modern slavery.

Human Rights Policy: New starters are familiarised with the company’s Human Rights Policy. Respect for Human Rights is fundamental to the sustainability of PREM Group and the businesses in which we operate. PREM Group acknowledges and respects the principles contained the United Nations Universal Declaration of Human Rights and Global Compact. The Human Rights Policy from PREM Group reflects the company’s commitment to conduct its business in a manner consistent with these principles and to respect Human Rights within the company’s sphere of influence.

Right to work: Checks are carried out on all team members to ensure the documents they provide are genuine and fit for purpose, in line with legislation. We ensure that our managers are provided with the tools and skills to carry out the necessary document checks sympathetically and appropriately.

Staff Handbook: This document outlines the Company code of conduct and is provided to all employees upon joining. The organisation's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

Equal opportunity policy: Outlines our commitment to provide equal opportunities and embrace diversity throughout employment.

Grievance policy: This process encourages concerns to be raised informally in the first instance in order to encourage an open and honest culture. However, it also outlines the formal process in the event that concerns cannot be resolved through the informal route, or in more serious cases where it is appropriate to deal with matters formally at the outset. The grievance policy provides clear guidelines on how individual can raise their concerns, along with what happen at that point and the potential outcome of any investigation into the issue raised.

Child Protection and Human Trafficking

Protecting victims of human trafficking is imperative to PREM Group. Through our partnership with Mecpaths, we take a public stand and work to prevent human trafficking and exploitation. We ensure all team members are trained in our human trafficking module. This module is part of our mandatory employee onboarding process. The module includes various case-based scenarios of forced labour and sex trafficking, training team members to identify suspicious behaviour and how to report forced sexual exploitation to police. It encourages discussion amongst participants on what actions to take.

Our Purchasing Supply Chain

Our purchasing supply chain is made up of the following elements:

  • Food and drinks for resale to our guests

  • Furniture, fixtures and equipment for use in our hotels

  • Hotel supplies not for resale (such as cleaning products, towels, bed linen etc.)

  • Service agreements covering items like maintenance and life safety

We partner with procurement specialists Trinity Purchasing who oversee our contractual arrangements with suppliers. We aim to use only market-leading suppliers for our main products, and a formal tendering and selection process is in place. At some properties, local suppliers are used, and PREM Group also approves these. Additional oversight is provided by the management responsible for the procurement area. It is standard procedure to have written contractual relationships with all of our suppliers.

Training

In addition to training new starters about the basic principles of Human Rights enshrined in our Human Rights policy, PREM Group also partners with a charity organisation called Mercy Efforts for Child Protection Against Trafficking with the Hospitality Sector (MECPATHS). This organisation collaborates with the hospitality sector to raise awareness around child trafficking and empower hotel management and staff to help counter this crime.

Future steps and ongoing commitment

The risks of modern slavery and human trafficking in our operations and in our supply chain need our constant attention. Because of the growth of our operations, we must continuously monitor and manage our supply chain risk. We will continue to minimise and manage the risks associated with modern slavery and develop better ways to increase the visibility of our actions in our operations and supply chain. In order to monitor and assess our compliance, in 2023 we plan a number of steps:

  1. A supplier code of conduct will be prepared and issued for all our suppliers. We expect our suppliers to commit to complying with this code of conduct.

  2. We will continue to conduct risk evaluations of suppliers of outsourced labour.

  3. Continue to encourage hotel teams to use the recruitment toolkit to identify any potential risks

  4. Include and update modern slavery elements in our existing manuals and contracts

  5. Whistleblowing policy: we will implement an internal whistleblowing policy, available in our hotels and support office. The company encourages all its workers to report any concerns related to the direct activities, or the supply chains of the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure will be designed to make it easy for workers to make disclosures, without fear of retaliation.

Jim Murphy

Chief Executive Officer

PREM Group