MODERN SLAVERY STATEMENT

 

This statement is made pursuant to s.54 of the Modern Slavery Act 2015.

It sets out the steps that CC STIM UK Holdco Ltd and its UK holding companies and

subsidiaries as defined in section 1159 of the Companies Act 2006 (“REKOM”) have

undertaken – and is continuing to take – to try to prevent modern slavery or human trafficking

from taking place within our business or supply chain.

We are committed to acting ethically and with integrity in all our business relationships and

this includes taking steps to work towards the removal of slavery and human trafficking from

our business and our supply chain. We are implementing effective systems and controls to

try and make sure that modern slavery does not take place anywhere within our business.

We are a UK based business and we are aware that modern slavery exists even in the UK,

so we cannot be complacent when it comes to these issues.

We are also committed to ensuring there is transparency in our own business and in our

approach to tackling modern slavery throughout our supply chains, consistent with our

disclosure obligations under the Modern Slavery Act 2015 (the “Act”).

 

Our organisation

REKOM is the UK’s largest operator of late-night bars and clubs, and as of September 2023,

operates approximately 50 premium venues across the country, trading under a number of

concepts including PRYZM, Vinyl, Fiction, ATIK, Bar & Beyond, Steinbeck & Shaw, District,

Proud Mary and Heidi’s. We employ circa 1,600 staff throughout our organisation.

 

Significant risks in our business

We are aware that the following areas of our supply chain and business are those where

there is a particularly high risk of modern slavery occurring:

 

1. Temporary or agency staff: We make use of temporary staff at our head office. As

these are not our employees, we are particularly vigilant in checking for signs of

slavery.

2. Operational and marketing consumables: These items are often manufactured in the

Far East and in areas of Europe where slavery has been identified in the past.

3. Food and drink suppliers: The total supply chain has a far reach covering a large

number of countries including those which have been identified as high risk.

 

4. Uniform suppliers: Clothing is produced both in the United Kingdom and in the Far

East.

 

Viewing our supply chain as a whole, the key suppliers that we consider represent a high

risk of modern slavery and/or human trafficking are found in the Far East, Russia, Brazil,

South America, North America, Spain, France, Portugal, Australia and the UK.

 

Our policies

We operate a number of internal policies to ensure that we are conducting business in an

ethical and transparent manner. These include:

1. Anti-slavery policy: This policy sets out our expectations of all employees and any

others who work in our business in relation to slavery and human trafficking issues,

including providing guidance on recognising modern slavery, and how employees

should raise any concerns they have. This policy can be found on the internal

document library in the modern slavery section.

2. Whistleblowing policy: This sets out the whistle blowing policy, so that all

employees know that they can raise concerns about how colleagues are being

treated, or practices within our business or supply chain, without fear of reprisals.

This policy can be found on the internal document library in the HR/whistleblowing

section. Our new purpose-built employee App also includes a section where

employees can raise these concerns.

3. Supplier Code of Conduct: This code sets out the minimum standard we expect all

our suppliers to take to work towards eradicating slavery and human trafficking in

their business and supply chain. More details on the Supplier Code of Conduct can

be found in the Supplier policy on the internal document library under the

procurement section. It is also available on our website.

 

Our suppliers

Our supply chain is varied, but our key tier 1 suppliers are those from whom we purchase

our alcoholic and non-alcoholic beverages, food, audio-visual equipment, and consumables.

Our supply chain is based globally and our suppliers themselves source globally.

 

REKOM operates a supplier policy and maintains a preferred supplier list, and we conduct

due diligence on all suppliers before allowing them to become a preferred supplier. During

the past year we have reviewed our supply chain and obtained statements on compliance

with the Act from all relevant suppliers. Those suppliers that were identified as medium-risk

or high-risk were sent questionnaires to complete to satisfy our audit requirements. The

responses to those questionnaires were reviewed and, where we had concerns, we either

met with suppliers to discuss the matter or the suppliers were asked to provide further

information until we were satisfied with their compliance with the Act.

 

Our Supplier Code of Conduct forms part of our contract with our suppliers and they are

required to confirm that no part of their business operations contradicts this policy. Suppliers

are also required to obtain confirmation from their own suppliers and sub- contractors that

they comply with the Supplier Code of Conduct.

 

The Supplier Code of Conduct requires suppliers to confirm the following relating to their

business and supply chain:

 

1. wages paid to workers are fair;

2. working hours and annual leave comply with national laws and industry

standards;

3. no child labour is used;

4. no forced, bonded, compulsory labour or servitude, or any form of human

trafficking is practiced;

5. abuse of workers is not tolerated;

6. a secure, safe and healthy working environment is provided;

7. freedom of association and collective bargaining is respected; and

8. local laws relating to discrimination are complied with.

 

Next Steps

Looking forward to next year, we will continue working with our suppliers to promote

awareness of slavery and human trafficking.

 

Approval for this statement

This statement was approved by the Board of Directors on 21-09-2023