Modern Day Slavery Policy
 

Dated: November 2021

As a UK based travel company operating in numerous countries across the globe, Sun-hat Villas & Resorts recognises it’s moral and ethical responsibilities to ensuring that our business and supply chain is slavery free. 

Sun-hat Villas & Resorts recognises that modern slavery and human trafficking is a serious global issue and affects all industries and sectors. We have policies and processes in place to prevent this directly within our organisation and we will continue to review our engagement with our supply chain to work towards tackling modern slavery.

This statement outlines our actions and activities regarding efforts to combat slavery and human trafficking within our business and supply chain.

Sun-hat Villas & Resorts

Sun-hat Villas is a leading vacation rentals and holiday resorts company mainly focused in Europe; specifically Portugal and the Algarve.

We have over 1,000 accommodation choices across 6 different countries and welcome thousands of holiday makers each year. Overall, we employ between 20 - 30 members of staff and as Sun-hat Villas continues to grow, we ensure that new additions to our portfolio are required to follow our policies and procedures.

Policies

Our Business Principles represent the core of our business philosophy requiring our employees to act both ethically and legally when dealing with fellow employees and third parties with whom we do business.

Slavery and human trafficking

This policy confirms Sun-hat Villas & Resorts is committed to ensuring that there is no modern slavery or human trafficking in any part of its business or its supply chains. Sun-hat Villas & Resorts operates the following policies for preventing human slavery and trafficking in our operations:

• Whistleblowing policy; we encourage all employees, customers and suppliers to report any suspicions of human slavery without fear of retaliation
• The Sun-hat Villas & Resorts Code of Conduct reflects our commitment to acting lawfully, ethically and with integrity in all our business relationships.
• Human Resources; our Recruitment Policy demonstrates our commitment to ensuring all our employees have the right to work and our approach to human slavery and trafficking.
• Supply chain; we request information from our suppliers regarding their approach to Modern Slavery, and would work with our suppliers in the event of any concerns identified.

Due Diligence and Risk Management

Sun-hat Villas & Resorts operates predominantly in the UK and Europe, with a strong focus on Portugal. Sun-hat Villas & Resorts recognises it’s moral and ethical responsibilities and continuously acts to ensure that we act lawfully in each country in which we operate.

Sun-hat Villas & Resorts acts as an agent for our supply chains, mainly consisting of resort representatives and holiday accommodation owners most of whom we engage with directly. As well as resort representatives and owners our supply chains also consist of agency, cleaning and caretaking staff, with whom we engage directly or via reputable agencies on behalf of our owners.

We have a zero tolerance policy to slavery and human trafficking. We encourage our employees to report certain matters confidentially or anonymously, including circumstances that may give rise to slavery or human trafficking concerns.

The Company's assessment suggests that the risks of slavery and human trafficking taking place in our supply chains are relatively low. We are, however, not complacent. Over the past year we have been implementing a process of due diligence.

We have:

• Reviewed and amended our standard terms of business and supplier qualification with the Company's supply chain and contractors, to ensure compliance with the Modern Slavery Act 2015
• Identified our key risk areas. These include; holiday representatives, agency workers cleaning and caretaking staff, all of which are mainly managed through third party agencies. We have brought this to the attention of our supply chain management and will we will continue to monitor their response throughout 2021/2022.
• Continued to manage the risks of Modern Slavery in recruitment of our permanent and fixed term staff.
• Provided our statement to customers and to internal staff through our website
• Evaluated the options for undertaking ethical audits of our supply chain

We conduct vendor risk assessments, which cover modern slavery and human trafficking, of our larger corporate suppliers, where applicable. In light of this, we believe there is a very low risk of slavery and human trafficking occurring in our business and supply chains.

Ongoing actions:

We also plan to continually reinforce our due diligence processes.  In particular, we will:

• Review our options for undertaking ethical audits of our supply chain, which may include third party assessment.
• Conduct a risk assessment of our supply chain taking into account; the risk profile of individual countries based on the Global Slavery Index, services rendered by suppliers and presence of vulnerable demographic groups.
• Evaluate the options for training to relevant members of staff to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business;
• Share this statement with all our staff through internal procedures, raising awareness of modern slavery and human trafficking. We will develop an appropriate training model, based on awareness and e-learning for our employees in 2022.
• Engage and work with those suppliers or contractors who identify modern slavery, or believe there is a risk to them or their supply chain from modern slavery in order to eliminate.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Slavery and Human Trafficking Statement for Sun-hat Villas & Resorts.

Sun-hat Villas will continue to look forward and develop our policies and practices for the better, we are committed to maintaining our commitment to combatting slavery and human trafficking by continuing to develop resources, refine our goals, and educate our employees across relevant areas of our business and supply chain. This is an ongoing process and to that end, we aspire to continue to work with the industry to make an impact within our sphere of influence.