Malvern Group Limited
Malvern Travel Limited’s Modern Slavery Statement can be viewed here.
Director’s Statement – Modern Slavery Act 2018 (the ‘MSA Act’)
This statement is made pursuant to the section 54 (1) of the Modern Slavery Act 2015 and constitutes Malvern Group Limited slavery and human trafficking statement for the financial year ending 31 March 2018.
This statement sets the Malvern Group Limited (‘Malvern Group’) actions to understand all potential modern slavery risks related to its individual business and to put in place steps that are aimed at ensuing that there is no slavery or human trafficking in its individual businesses and their supply chains. This statement relates to actions and activities during the financial year 1 April 2017 to 31 March 2018.
As part of the travel industry, Malvern Group recognises that it has a responsibility to take a robust approach to slavery and human trafficking. Malvern Group Limited is committed to preventing slavery and human trafficking in its corporate activities and within its individual businesses, in order to ensure that its supply chains are free from slavery and human trafficking.
Organisational structure and supply chains
This statement covers the activities of Malvern Group and its businesses within the group:
- Late Rooms Limited (‘LateRooms’)– an online travel agent facilitating bookings for accommodation only.
- Super Break Mini Holidays Limited (‘Super Break’) – a short break specialist providing 2-5 star hotels, rail travel, Eurostar travel, flights and mini cruises, plus additional extras including theatre, concerts and various other attractions.
- Malvern Travel Technology (MTT) – Owner of the Wizian platform, powering the delivery of travel propositions for our corporate partners. All breaks sold through the platform are facilitated by Super Break Mini Holidays Limited and all policies apply,
Countries of operation and supply
LateRooms and Super Break currently operates in the following countries:
LateRooms – currently operates in the United Kingdom but can take bookings from consumers based anywhere worldwide and for hotels worldwide, although 94% of bookings are from UK consumers for UK Bookings.
SuperBreak currently operates in the United Kingdom but its customers travel to the following countries: Australia, Austria, Belgium, Bulgaria, Canada, Channel Islands, Croatia, Cyprus, Czech Republic, Denmark, Egypt, England, Estonia, Finland, France, Germany, Gibraltar, Greece, Hong Kong, Hungary, Iceland, India, Ireland, Israel, Italy, Jordan, Latvia, Lithuania, Luxembourg, Malaysia, Malta, Monaco, Morocco, Northern Ireland, Norway, Oman, Poland, Portugal, Puerto Rico, Qatar, Romania, Russia, Scotland, Serbia, Singapore, Slovakia, Slovenia, South Africa, Spain, Sweden, Switzerland, Thailand, The Netherlands, United Arab Emirates, United States of America, and Wales.
Risk Assessment Process
The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:
- Modern Slavery Act meetings take place across the business, including at parent level the attendance of Malvern Group directors. Each individual business has had a ‘top up meeting’ within the individual business where the action plans are developed;
- A contractual clause on the MSA Act for inclusion within supplier contracts was proposed and distributed to the businesses within the group. Zero tolerance for modern slavery and respect for human rights is being built into supplier contracts and also represented in dialogue, sub-contractors, customers and other business partners.
High- risk activities
- As a non operational entity, Malvern Group does not view any of its activities as high risk. High, Medium and Low risks are identified in our individual businesses’ statement, links to which are provided at the end of this statement.
Malvern Group operates the following group policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Modern Slavery Act Policy In accordance with the MSA Act. Malvern Group has adopted a group led policy relating to anti-slavery and human trafficking. The policy confirms Malvern Group’s commitment to tackling slavery and human trafficking throughout our supply chains and to ensure transparency in Malvern Group’s individual businesses. We expect the same high standards from our businesses, contractors, suppliers and other business partners.
- Anti Bribery & Whistleblowing policy Malvern Group encourages all of its employees, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, any of its individual businesses. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Malvern Group whistleblowing procedure is designed to make it easy for employees at any level to make disclosures, without fear of retaliation.
Malvern Group has requested each business to review its key performance indicators (KPI’s) in light of the introduction of the MSA Act. As a result, specific KPI’s have been identified to measure supplier effectiveness and compliance following the implementation of the MSA Act by:
- Developing a system for supply chain verification whereby the organisation evaluates potential new suppliers before they enter the supply chain and
- Reviewing its existing supply chains to be completed over the next number of years, whereby the organisation evaluates all its existing suppliers.
Malvern Group has required each of its businesses to roll out an awareness-raising training programme to all of its staff:
The briefing will explain to staff:
- the basic principles of the MSA Act and how it impacts their businesses.
- how employers can identify and prevent slavery and human trafficking; and
- what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the businesses.
This statement has been approved by Malvern Group Limited’s board of directors, who will review and update it annually.
Date: 28th Feb 2019
Additional links for our businesses MSA Act Directors’ Statements:
Late Rooms Limited:
Super Break Mini Holidays Limited:
Malvern Travel Limited