Modern Slavery and Human Trafficking Statement
Modern Slavery Statement
The Caravan and Motorhome Club is the largest private membership organisation in the UK that provides its members with a full range of products and services in connection with caravan and motorhome touring and actively promotes enjoyment of the great outdoors. The five main areas of operation are Membership, UK Touring Sites, Financial Services, Overseas Travel and Advice, Support and Member Offers. Established in 1907, the Club network has approximately 200 UK sites. The Club is a member-owned organisation which re-invests any surplus into improving and providing facilities and services for its members. The majority of the Club’s operations are UK based, whether provided directly by the Club or through arrangements with UK based partners.
The Caravan and Motorhome Club is committed to ensuring that there is no modern slavery or human trafficking in its supply chains or in any part of its activities, putting in place effective systems and controls to safeguard against this and will develop appropriate key performance indicators to evaluate the success of its activities.
Recruitment
There are over 400 staff at Head Office in East Grinstead and a further 800 permanently employed staff with a seasonal work pattern who operate the Club’s touring sites network. The Club does not generally recruit its staff from outside the UK population as it is usually able to meet its requirements from within the UK. The Club ensures that all potential employees fully comply with UK Visas and Immigration (UKVI) ‘right to work’ checks. Where employment from outside of the UK might be required, the Club will ensure that all the necessary licences are in place to enable sponsorship of non UK Nationals, Visas are provided, and the appropriate right to work checks are undertaken in order to comply with UK Government requirements.
Policies
Among the internal policies that help ensure we are conducting business in an ethical and transparent manner, avoiding modern slavery or human trafficking, are:
- Equality and Diversity Policy
- Recruitment Policy
- Right to Work Policy
- Whistleblowing Policy
- Health and Safety Policies
- Fraud and Anti-Bribery Policy (including gifts and hospitality)
- Procurement Policy
These policies and procedures are kept under regular review.
Supply Chain
The Caravan and Motorhome Club has approximately 3,000 active suppliers providing a range of goods and services. The Club operates a procurement policy in conjunction with an approved supplier list. Due diligence is conducted on suppliers before they are approved. This requires suppliers to comply with numerous conditions including employment, working conditions, fair wages, working hours and ethical practices. New contracts, tenders, terms and conditions include the appropriate statements relating to the Modern Slavery Act 2015. The Club is enhancing the due diligence process by including an online search to identify if a supplier has been convicted of any offences relating to modern slavery and reviewing their own modern slavery statements on their websites (where they have a turnover in excess of £36m).
Risk Assessment
Due to its extensive supply chain, the Club recognises that it will take some time to fully develop its approach and processes in a proportionate manner relative to the risk. There is generally a low risk of slavery associated with the industries with which the Club works within its supply chain. The Club has in place proportionate systems to identify and assess, mitigate and monitor potential risk areas in its supply chains and the Club’s ethical approach avoids engaging with unethical suppliers irrespective of the associated cost for the goods or service. However, the Club cannot be fully confident that all risks are completely mitigated due to the extensive nature of the supply chain and the fact the approach continues to be developed.
Training and Awareness
To ensure a high level of understanding of the risks of modern slavery and human trafficking in the Club’s operations and supply chain, it continues to develop and offer training packages, including online modules which will be rolled out to specific staff responsible for procurement, supply chain performance, recruitment and management of staff. More general awareness information and training will be given to all remaining staff over time through the Club’s normal communication channels. This will include how to assess the risk, identify the signs and the appropriate action to take when concerns about potential or suspected instances of slavery or human trafficking arise.
The Club’s Executive Committee, through the Director General, holds senior management accountable for communicating ethics and compliance expectations.
Declaration
This statement is made pursuant to Section 54(1) of the Act for the financial year ending 31 December 2023. It was approved by the Club’s Executive Committee on 24 June 2024.
Signed by David Turner, Chairman
24 June 2024