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Anti Slavery Policy

About this Policy

The purpose of this policy is to set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on modern slavery and human trafficking; and provide information to those working for and on our behalf on how to identify and report concerns regarding modern slavery and human trafficking.

The intention and spirit of this policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. We shall go to every reasonable length to ensure the third parties we work with adopt and follow the same Anti-Slavery values as The Conte Club. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy or the spirit of the responsibilities it seeks to uphold.

This policy does not form part of any employee's contract of employment and we may amend it at any time.

At The Conte Club we are deeply committed to ensuring that we operate an ethical and responsible approach to the places our guests travel and the business partnerships we engage. We believe that when our guests travel around the world that they should give to, not take from, the places they visit in order to have a positive effect on the people and cultures of those destinations. We are committed to taking steps to ensure that slavery and human trafficking does not occur within the course of our business or in the operations of our partners in accordance with the Modern Slavery Act 2015. Furthermore we are committed to being ambassadors of supporting and upholding human rights throughout our company and global network.

Ensuring a like-minded and responsible network

 

We are committed to ensuring that our global network of partners are making their own commitment to ethical and responsible policy making to ensure the tenants of Modern Slavery Policies also run through their own operations. We work with suppliers of: luxury travel accommodations, travel experiences, transport (including yachts and private, commercial airlines), private guides and local businesses around the world and ensure we undertake clear due diligence to audit our travel partners commitment to the same working ethos and values as described herein.

We expect the same high standards from all of our contractors, suppliers and other business partners and, as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

Company Wide Commitment

 

We communicate to our staff, suppliers and other businesses why it is vital for companies to take steps to eliminate slavery from their supply chains. We are transparent and proud in our support and commitment to the Modern Slavery Act for all of our employees and have established internal practices and put procedures in place for any employee who wishes to raise or discuss any concerns they have regarding the issues covered by our Modern Slavery Policy statement.

Measuring our Due Diligence

In order to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains we have used 3 key indicators to help us be accountable and transparent in our practice.

  • the number of partnership proposals we have declined based on a lack of policy on this issue, or an unwillingness to implement one.

  • the number of our employees trained on human rights, modern slavery and human trafficking;

  • the number of supplier audits carried out.

Our Responsibilities and how to raise a concern

 

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify admin@theconteclub.com as soon as possible if you believe or suspect that a breach of this policy has occurred, or may occur in the future. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately.

Breaches of this Policy

 

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

 

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Our Modern Slavery Act statement on the TISCreport.org and modernslaveryregistry.org websites. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps that The Conte Club has taken to prevent modern slavery and human traf icking in it's business operations and supply chains.

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