Maverick Topco limited (trading as Riviera Travel)
SLAVERY AND HUMAN TRAFFICKING STATEMENT
March 2024
- Introduction
Modern slavery is a crime resulting in an abhorrent abuse of human rights. This statement
has been prepared in accordance with section 54 of the Modern Slavery Act 2015 and outlines
how the Company proactively manages and assesses its own operations alongside our
suppliers to protect workers from being abused and exploited in our own Company and our
supply chain. - Responsibility
Whilst it is every employee’s responsibility to be aware of and highlight any areas of
potential risk, overall responsibility for ensuring that the Company, it’s associated
organisations and supply chain are compliant in relation to the Modern Slavery Act 2015 lies
with the Chief Executive Officer. - 3. Business Structure
Our core business is the organisation, administration and provision of worldwide escorted
tours, ocean and river cruises. Our head office is based at New Manor, 328 Wetmore Road,
Burton-upon-Trent, DE14 1SP where all our central functions (Sales & Marketing, Operations,
Product, Finance, Technology, HR, Customer Service and Contact Centre) are located,
employing approximately 250 staff (this number can increase and decrease according to
seasonal fluctuations).
We also utilise the services of self-employed Tour Managers and Cruise Directors who are
located throughout the world and these number some 300. - Supply Chain
Our supply chain includes the sourcing of accommodation & transport services, either
directly or via a local Destination Management Company (“DMC”) in each country we operate
in. With respect to DMCs we ensure that these are long-established and/or multi-country
entities with robust working practices – however, they neither own nor directly operate the
hotels or transport used.
Typical workers within the supply chain will include those in the travel sector, such as selfemployed tour managers and cruise directors who are geographically dispersed. The supply
chain also includes employees and contractors of the partners we engage to provide and
operate our cruise ships. We work with a wide network of hoteliers, ranging from
multinational corporate providers to local area independents. Our supply chain will also
include a large network of travel agents and other commercial partners who broker sales
and market our product. These suppliers will have a range of employment practices in
accordance with their location, scale and the type of role they are engaging. - Policy
We are committed to social and environmental responsibility and have zero tolerance for
slavery and human trafficking. We hold ourselves and our supply chain accountable and we
fully comply with the provision of the Modern Slavery Act 2015.
We recognise that modern slavery is a complex supply chain issue and we work in partnership
with our customers, suppliers and other organisations to sustain long-term solutions to this
issue.
We are committed to acting ethically and with integrity in all our business relationships and
to implement and enforce effective systems and controls to ensure slavery and human
trafficking is not taking place anywhere in our supply chain.
In 2022 we will update our Modern Slavery policy and provide awareness training for our
employees. The need to do this now is particularly important given that there has been a
significant influx of new joiners to the business in the last 12 months. - Due Diligence in our Supply Chain
6.1 Risk Assessment
The risk of slavery and human trafficking within our own organisation is substantially avoided
and mitigated as a result of strict policies and procedures as well as the controls built into
our business operations and the knowledge and skills of our staff. We assess risk based on a
number of factors including geographical risk indices pertaining to human rights, the level
of supply chain control, external governance factors and levels of political stability.
Given that the vast majority of our employees are based in our Burton office, we consider
that the greatest risk of slavery and human trafficking is in our supply chain where we
undertake procurement activities and where operations and managerial oversight are out of
our direct control. As identified earlier in this statement, we consider that the risk of
slavery and human trafficking may have increased in our supply chain as a result of the
scarcity of workers and increased vacancies combined with the uptick in demand for
holidays.
6.2 Due diligence
As part of our initiative to identify and mitigate risk:
• Where possible we build long standing relationships with local suppliers and make
clear our expectations of business behaviour;
• We undertake all reasonable and practical steps, including accommodation
inspections and audits, to ensure that our standards are being implemented
throughout the businesses of our suppliers and that local legislation and regulations
are complied with;
• With regards to national or international supply chains, our point of contact is
preferably with a UK company or branch and we expect these entities to have
suitable anti-slavery and human trafficking policies and processes;
• We expect each entity in the extended supply chain to at least, adopt ‘one-up’ due
diligence on the next link in the chain. It is not practical for us (and every other
participant in the chain) to have a direct relationship with all links in the supply
chain;
• It is a contractual requirement for our hotel suppliers to comply with relevant
legislation in relation to modern slavery and to comply with the Company’s
standards. Failure to do so may result in termination of the supplier agreement;
• Our suppliers are required to sign a declaration of their adherence with the
requirements of the Modern Slavery Act 2015 and Riviera’s expectations. We are
currently reviewing our process with a view to implementing a standard, robust
approach for new and existing suppliers;
• Many of our suppliers are strictly regulated and audited on a regular basis. There
are regular inspections by the police onboard the ships we use. These inspections
are specifically in relation to working conditions;
• For some countries, accommodation & transport services are obtained via a local
Destination Management Company (DMC). With respect to DMC’s we ensure that
these are long-established and/or multi-country entities with robust working
practices – however, they neither own nor directly operate the hotels or transport
used. - Involvement in Modern Slavery
Since the last statement was published, we have not been made aware of any concerns or
potential issues from anywhere within our supply chain. Should we be made aware of any
potential instances or issues, we will assess them on a case-by-case basis and will consider
appropriate action.
Should our investigations identify a breach of our requirements or those of modern slavery
legislation, or treatment of workers which falls short of our expectations, we would
investigate the situation thoroughly and engage external agencies if appropriate. We will
only trade with those who fully comply with this statement or those who are taking verifiable
steps towards compliance.
We reserve the right to terminate our relationship with a supplier if issues of noncompliance
with our policies or our moral obligations are discovered and those issues are not addressed
in a timely manner. - Training & Awareness
We will ensure that we have competent individuals within our Company who are aware of
the standards we require and are able to provide guidance and support to all employees to
ensure they have an understanding of the expected behaviour from both our Company and
that of our supply chain. - Key Performance Indicators
In the next review period we are committed to the following:
1. Reviewing and updating our Modern Slavery Policy
2. Raising awareness of the risks of slavery and human trafficking amongst our
employees by communicating our revised policy and undertaking relevant training
3. Rolling out awareness training to our self-employed tour manager and cruise director
population
4. Creating a clear process for raising concerns and encouraging it’s use
Over the course of the next year we will look to identify further actions to support our
supply chain due diligence.
We will report on progress in relation to these commitments in our next statement. - Whistleblowing
We encourage anyone who has a concern to raise it in the first instance with their Riviera
contact.
We have in place a Whistleblowing Policy which is applicable to employees, contractors,
suppliers and other partners to Riviera Travel where this is not possible, for whatever
reason. - Review
This statement will be reviewed annually, unless circumstances dictate that it should be
reviewed and/or renewed more frequently. - Authorised Signatory
This statement is approved by Phil Hullah, Chief Executive Officer, Riviera Tours Limited
(trading as Riviera Travel).