Modern Slavery Policy

WHO WE ARE

As a business with a turnover of less than £36m, Visit Kent Limited and Go To Places Limited
(‘the Group’ or ‘the organisation’) is not required to publish a statement. However the
organisation would like to make it known that it has a zero-tolerance approach to modern
slavery and will never engage in these heinous activities. The organisation will condemn
others who engage in such activities, and will not knowingly engage with anyone or any
business who does so.

PRIVACY POLICY

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, suppliers and
business partners.
Failure to comply with this policy may result in disciplinary action, including dismissal or
termination of your contract with the Group. It could also involve other legal steps being
taken against you.
This policy is not part of any employment contract. This policy may be amended at any
time

WHAT IS MODERN SLAVERY?

Also referred to as ‘slavery’, ‘child labour’ and/or ‘human-trafficking’, modern slavery is a
crime and a violation of fundamental human rights. It takes various forms, such as slavery,
servitude, forced and compulsory labour and human trafficking, all of which have in
common the deprivation of a person's liberty by another, in order to exploit them for
personal or commercial gain.

PERSONNEL RESPONSIBLE FOR THIS POLICY

The Visit Kent Board of Directors (the ‘Board’) has overall responsibility for the effective
operation of this policy and for ensuring compliance with legislation. The Board has
delegated day to day responsibility for operating the policy and ensuring its maintenance
and review to the Head of Operations. All employees, workers and consultants are
expected to be committed to the aims of this policy.

PREVENTION OF PROHIBITED ACTIVITIES

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 and with the Group. You are
required to avoid any activity that might lead to, or suggest, a breach of this policy.

The Group ensures that the appropriate checks are made on all employees, to be certain
who is working for, or on behalf of, the organisation and that they are permitted to work
and paid fully and fairly for what they do.

All our employees are paid fairly according to legal requirements, the arrangements for
which are properly and lawfully set out in their written contracts of employment.
The health and safety of all of our employees and workers is also of paramount importance
to the Group, and we take our legal obligations very seriously, including in relation to
working hours, rest breaks, and holidays. 

REPORTING CONFLICTS OF THIS POLICY

You must notify the Head of Operations as soon as possible if you believe or suspect that a
conflict with this policy has occurred, or may occur, in any of our business activities or
supply chains, in the future.

If you are unsure about whether a particular act, the treatment of workers more generally,
or their working conditions within any tier of our supply chains constitutes any of the
various forms of modern slavery, please discuss this with a member of the senior team.

The Head of Operations will take any report made to them very seriously and will promptly
and responsibly investigate the allegations made or suspicions shared. They will make
recommendations to and agree with our Board on the actions that should be taken
following any such investigation.

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 Head of
Operations immediately. If the matter is not remedied, and you are an employee, you
should raise it formally using our grievance procedure, which can be found set out in our
Grievance Policy.

STAKEHOLDERS AND SUPPLIERS

We expect all of our stakeholders and suppliers to share a similarly uncompromising
commitment to the same levels of compliance as we have set out in this policy.

We take a risk-based approach to our contracting processes and where appropriate may
write to suppliers requiring them to comply with this policy, which sets out the minimum
standards required to combat modern slavery and trafficking.

Consistent with our risk-based approach we may also require suppliers engaging workers
through a third party to obtain that third parties’ agreement to adhere to the policy.
As part of our ongoing risk assessment and due diligence processes we will consider
whether circumstances warrant us carrying out audits of suppliers for their compliance with
our policy.

If we discover that any business or individual associated in any way with our business is
engaged in, or otherwise supporting, and/or condoning or failing to prevent such activities,
when such activities are within their control and/or influence, we will cease all connection
with them. We will also consider whether we are under any reporting or other legal duty in
respect of this disassociation and our reasons for it.

POLICY REVIEW

This policy will be reviewed on a regular basis to ensure compliance with legislation and to
identify any further opportunities to help eradicate modern slavery.