Modern Slavery Act | The Belfry Hotel & Resort

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The Belfry Hotel Resort



TB Resort Operations Ltd trading as “The Belfry”, Wishaw, Sutton Coldfield, West Midlands B76 9PR is publishing this statement in compliance with Section 54 of the Modern Slavery Act 2015. This statement is made for the financial year ending 2019 and details the steps taken by The Belfry during this year.

Organisational Structure
The Belfry is a trading name for TB Resort Operations Ltd which is based in the United Kingdom. This statement is made by The Belfry as the company that actively carries out business in the UK on behalf of the Company.
The Belfry is a UK-based company operating from a single site location in the UK. We employ around 715 employees. Our hotel and resort provides full hotel services including bedrooms, golf, spas and leisure and gym facilities with significant food and beverage offerings.
The Resort had an annual worldwide turnover of £36.1 million in 2019 (all from within the UK).

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 we take seriously.

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 Modern Slavery Act 2015 Statement 2 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:

● having a high percentage of staff who are from overseas;

● having a transient workforce;

● having a diverse supply chain.


We procure goods and services directly from over 200 first tier UK based suppliers in three main areas; Furniture, fixtures and equipment, food and beverage and operational supplies (goods not for re-sale).

We have contractual relationships with all of our suppliers and a dedicated procurement department to oversee the instruction of major supplier agreements and ensure that adequate procedures are in place.

We subcontract general maintenance and construction works services to a number of small providers in the UK. When carrying out building work, we currently contract with one main UK based contractor who will then subcontract elements of the construction work.

We have a number of low tier indirect suppliers throughout the world, primarily related to our food and beverage offering.

We employ the majority of our workforce directly; we have a small number of independent agents working for The Belfry. These independent agents tend to be spa therapists or personal trainers (based in the gym facilities at our hotels). All independent agents are contracted with directly or via an employment agency.

We recognise that effective policies are crucial for combatting Modern Slavery. We are committed to ensuring we are not supplied by anyone who engages in human trafficking and modern slavery.
Our Right to Work Policy and Recruitment Policy are followed to ensure, as far as possible, that migrant workers are not exposed to exploitation and that the business is not exposed to the fraudulent recruitment of employees.

We also operate a Whistleblowing Policy aimed at employees which encourages staff to report any wrongdoing. We intend to extend this policy to our wider supply chain.
The Board of Directors has overall responsibility for our Modern Slavery policies.

In 2019 we sought to identify and address risks of Modern Slavery in our supply chain and we have:

● Carried out a first tier risk supplier mapping exercise in order to identify suppliers that fall within an area that is at high risk of Modern Slavery, and we have addressed Modern Slavery with these suppliers by requesting copies of their policies and procedures and advising them that there will be an audit trail in place over the next year for dealing with compliance.

● Addressed Modern Slavery as a formal business risk and put in place a mitigation plan that will be reviewed at quarterly meetings and owned by Heads of Departments within the business who will manage those mitigation plans.

● Reviewed our procurement processes to identify Modern Slavery as a risk to be identified and assessed on supplier audits.

● Ensured the Right to Work policy is followed with strict compliance.

● Reviewed our policies on Modern Slavery and considered implementation.

In 2019 we have taken the following steps:

● Included training on the risks of Modern Slavery into our induction for Senior Roles.

● Reviewed our recruitment process considering Modern Slavery as a risk.

● Engaged with the Gangmasters and Labour Abuse Authority (GLAA) to develop hotel specific guidance for employees and the potential exposure to Modern Slavery within hospitality.
During 2020 / 2021 we will:

● Provide and develop training that is specific to our business during 2020 / 2021.

● Implement an online training tool for all employees to allow them to understand that Modern Slavery is a risk within hospitality.

Carry out risk assessments and monitor our supplier tiers and carry out audits.

This statement has been approved by the Board of TB Resort Operations Ltd trading as “The Belfry”, and is signed by Chris Eigelaar as Resort General Manager of The Belfry Hotel & Resort.

Chris Eigelaar