UK Modern Slavery Act

Date:      September 3, 2018
Subject:    UK Modern Slavery Act (“MSA”) Statement

BridgeStreet is committed to good corporate citizenship and the highest ethical standards. To fulfil these requirements, BridgeStreet has established and maintains systems and controls to ensure that slavery and related human trafficking do not form part of our supply chain.

Anti-Slavery Statement

Ethical Commitment

BridgeStreet Global Hospitality (“BridgeStreet”) is opposed to slavery and human trafficking and is committed to making meaningful improvements to sustainable workplace conditions and business practices including, but not limited to, the prevention of forced or trafficked labour.  Through modifying our own operations and encouraging our suppliers to do so, we consider the social, environmental and financial impact of our business throughout our supply chain. We are joining our industry peers in global initiatives that drive corporate responsibility throughout the hospitality industry.
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (the “Act”) and constitutes our slavery and human trafficking statement for the financial year ending 2018.  It sets out the steps BridgeStreet has taken and intends to take to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.  
Our Business
With properties in more than 22,674 cities, in over 131 countries, BridgeStreet is the first unified technology platform built for business travel offering access to extended stay hotels, hostels, serviced apartments, vacation rentals, homes and hotels. 
Our Supply Chains and Due Diligence Processes 
Examples of our supply chain include agency workers, laundry services, waste removal services and building and maintenance service. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our working practices reflect our commitment to acting ethically and with integrity in all our business relationships and to maintaining effective systems to ensure forced labour or trafficking is not taking place anywhere in our supply chains. 
Policies and Risk Assessment 

We have comprehensive policies in place to help ensure our business is conducted according to rigorous ethical, moral, professional and legal standards. For example: 
Whistleblowing Policy: We encourage all our employees, workers, customers and other business partners to report any concerns related to our direct activities or supply chains. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can contact an external and anonymous helpline; and 

Anti-bribery Policy: Our policy confirms BridgeStreet’s zero tolerance of bribery and corruption and extends to all business dealings and transactions. All employees, officers, agents or consultants or any persons or companies acting for BridgeStreet or on our behalf are expected to adhere to this policy.

Our Alliances and Partnerships
We understand that our contribution will count more if we act in concert with others.  Therefore, we are joining our industry peers in global initiatives that drive corporate responsibility throughout the hospitality industry.  
We favour long-term partnerships with our suppliers and work with them to improve the sustainability criteria of our supply chain and continue searching for new solutions and alternatives.
Future steps
It is important that our policies and procedures relating to the prevention of modern slavery and human trafficking evolve in line with best practice and changing circumstances. To that end we will be taking the following steps to ensure we are compliant with the law.
We aim to contact our suppliers asking them to reconfirm to us that there is no modern slavery or human trafficking in their supply chains or business and that they have adequate systems in place to identify, assess, monitor and mitigate potential risk areas in their business and supply chains and to protect whistle blowers. 
We aim to widen the scope of our whistleblowing policy to specifically include reporting on modern slavery and human trafficking. 
We will commence the development of a formal modern slavery policy. 
We hope to introduce training on modern slavery and human trafficking for all employees. We understand that training is a fundamental way to raise awareness and to effectively implement the organisation’s commitment to fair working practices. 
We will develop a code of practice for engaging new suppliers. This will include requirements for pre-contract due diligence to be carried out in relation to a supplier and a requirement that all contracts include provisions for compliance with UK legislation and for termination if the supplier violates any laws which prohibit forced labour, slavery and human trafficking. 
We will continue to update our policies and procedures on an ongoing basis to ensure we maintain appropriate safeguards against the mistreatment of persons involved in our business or supply chain. 

Stephen Burns
Managing Director, EMEA/APAC