Modern Slavery and Human Trafficking 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 Marketing Services. Established in 1907, the Club network has over 2,700 sites and locations in the UK and Europe. The Club is a not-for-profit organisation which invests any profits 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. Where the Club operates overseas, its operations are mainly in Europe.
The Caravan and Motorhome Club is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our 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.
There are around 400 staff at Head Office in East Grinstead and another 600+ permanently employed staff with a seasonal work pattern who operate the Club’s touring sites network. The Club does not recruit its staff from outside the UK population as it is able to meet its requirements within the UK. The Club ensures that all potential employees fully comply with UK Visas and Immigration (UKVI) ‘right to work’ checks.
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
- Gifts and Hospitality
- Recruitment Policy
- Right to Work Policy
- Whistleblowing Policy
- Health and Safety Policies
- Fraud and Anti-Bribery Policy
- Purchasing Policy
These policies and procedures are kept under regular review.
The Caravan and Motorhome Club has approximately 3,000 active suppliers providing a range of goods and services. The Club operates a purchasing 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 now include the appropriate statements relating to the Modern Slavery Act 2015. The Club is looking to enhance 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).
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 is not fully 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 training packages 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.
This statement is made pursuant to Section 54(1) of the Act for the financial year ending 31 December 2018. It has been approved by the Club’s Executive Committee on 24 June 2019.
Signed by Nick Lomas, Director General
24 June 2019