Modern Slavery Statement

MODERN SLAVERY ACT POLICY STATEMENT for the financial year ending 28 February 2024

This statement sets out the steps taken by Snug Bars during the financial year to ensure our business and supply chain are free from slavery and human trafficking and is made pursuant to Section 54 of the Modern Slavery Act, with the objective of encouraging greater transparency for all stakeholders on the measures taken to combat slavery and human trafficking within businesses and their supply chains.

Group policy on slavery and human trafficking

Snug Bars are committed to doing business with respect for human rights and to implementing and enforcing effective systems and controls to guarantee that human rights are not being breached. Snug Bars does not tolerate forced, bonded or involuntary labour.

The Group is committed to ensuring that we supply high quality products that are sourced and manufactured in a fair, ethical and environmentally responsible way. We have a zero-tolerance approach towards modern slavery and human trafficking within our business, including our supply chain. Our workers are encouraged to report any concerns they may have, and management is required to act upon them.

Our Business

Snug Bars is a leading, cocktail bar business in the home counties.

Our main office is based in St Albans.

 

Recruitment and whistleblowing

As part of our commitment to ensuring that there is no modern slavery or human trafficking in our business or supply chain, we implement the following internal policies to ensure that we are conducting business in an ethical and transparent manner:

• Recruitment – we conduct robust checks on any new employee including eligibility to work in the UK to safeguard against human trafficking or individuals being forced to work against their will.

• Vault – we have a zero-tolerance policy for all forms of bullying, harassment and discrimination, and we want to ensure that everyone has the ability to speak up about injustices they may experience or witness.

 

 

Supply chain due diligence and risk assessment

We understand the potential risk of modern slavery taking place in our supply chain. To mitigate any unethical behaviour, as part of our supplier on-boarding process, we carry out a formal supplier approval process across our supply base, which includes a focus upon human rights and labour standards policies. We also carry out audits of our supply base on a periodic basis.

Employee awareness and training

Both Directors, together with colleagues across all business units, including in our People and Support teams, receive training on a periodic basis to ensure that they understand the importance of ethical behaviour and the risks of modern slavery and human trafficking, such that it remains at the forefront of their minds when carrying out their duties.

An externally facilitated training module, designed to raise colleagues’ awareness of modern slavery and human trafficking and to help colleagues recognise their role in identifying and reporting any concerns, has been completed by colleagues in the past year.

Compliance with this policy

This policy applies to all colleagues, but also to consultants and contractors in relation to their work for, or on behalf of, Snug. Failure to comply with this policy may result in disciplinary action being taken against any colleagues concerned or the termination of contracts with contractors working for any business unit.

We expect our suppliers to support our commitment to safeguarding human rights, including the Group’s approach to forced, bonded or involuntary labour. To ensure adherence to and continual improvement of this policy, we reserve the right to visit and assess our suppliers’ commitment to the policy. We reserve the right to terminate any agreements should a supplier decide that compliance with this policy is impossible or where a supplier fails to comply with the provisions of this policy.

The company confirms there were no concerns raised in FY22 regarding modern slavery, child labour or human trafficking.

APPROVAL OF THIS STATEMENT

This statement has been approved by the Board of Directors
Giles Fry & Jonathon Grenville-Grey

Date: 19th September 2023