Modern Slavery & Human Trafficking Policy & Procedure
Bolsover Cruise Club is the UK’s favourite cruise agent and has been named Top UK Independent Agent for P&O Cruises for 32 consecutive years. Family-owned and founded in 1960, we’re completely independent and unlike many travel agents, we specialise in cruise holidays. We work cruise lines from across the globe, including brands in the United Kingdom, United States, Europe and Asia.
The United Kingdom’s Modern Slavery Act 2015 requires UK companies to disclose information regarding our efforts to combat slavery and human trafficking within our business and any elements of our supply chain. At Bolsover Cruise Club, we take this responsibility very seriously.
Our Policy Statement
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. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships and to implement and enforce effective systems and controls to ensure modem slavery is not taking place anywhere in our business or supply chain. We are also committed to ensuring there is transparency in our business and in our approach to tackling modern slavery throughout our supply chain.
We expect the same high standards from all of our contractors, suppliers and other business partners. 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 and we expect that our suppliers will hold their own suppliers to the same high standards.
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, agents, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee’s Contract of Employment and we may amend it from time to time.
Responsibility for the Policy
The directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
Managers, as instructed by the directors, have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modem slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given any required training.
Compliance with the Policy
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 chain 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 your manager OR director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
You are encouraged to raise concerns about any issue of suspicion of modern slavery in any parts of our business or the supply chains of any supplier tier at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or director or report it in accordance with our Whistleblowing Policy as soon as possible.
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 chain constitutes any of the various forms of modern slavery, raise it with your manager or director.
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 part of our supply chain. If you believe that you have suffered any such treatment, you should inform your manager immediately.
We apply risk-based due diligence to our relationships with business partners. We decline to enter or continue business with any business partners who fail to complete the required due diligence or who fail to meet our standards.
Communication and Awareness of Policy
Training on this policy, and on the risk our business faces from modern slavery in its supply chain will be given where needed and the policy will be published in our Employee Handbook for our employees’ reference.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
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.
The Public Interest Disclosure Act (PIDA) 1998 protects employees (whistle-blowers) who report wrongdoing within the workplace, but it is the aim of this policy to ensure that as far as possible our employees are able to tell us about any wrongdoing at work which they believe has occurred or is likely to occur.
We recognise that employees may not always feel comfortable about discussing their concerns internally, especially if they believe that the company itself is responsible for the wrongdoing. The aim of this policy is to ensure that employees are confident that they can raise a matter with the appropriate manager within the organisation.