POLICIES

Modern Slavery and human trafficking statement
Sanderson – St Martins Lane

This statement is made pursuant to s. 54 of the Modern Slavery Act 2015 in the United Kingdom (the “Act”) for the financial year ending 31 December 2019 and sets out the steps that SBE ENT Holdings, LLC and its affiliates (together, “we”, “us” or “sbe”) have taken and are continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chains.

The Act creates offences in respect of slavery, servitude, forced or compulsory labour and human trafficking (“Modern Slavery”). We are committed to monitoring our practices to ensure that slavery and human trafficking are not taking place in any of our supply chains or in any part of our business. We expect the same high standards from all of our contractors, suppliers and other business partners.

About sbe

sbe is a lifestyle hospitality company which is at the forefront of hospitality, cuisine, design, residences and entertainment through developing, managing and operating hotels, residences, restaurants and nightclubs. sbe features a portfolio of world-class international lifestyle hotels in global markets such as Los Angeles, New York, Las Vegas, Miami, San Francisco, Istanbul and London, in addition to residential properties within North America.

Our staff

All staff employed by sbe entities in the UK are subject to right to work checks in line with UK legislation. A person is unable to commence work for sbe unless they satisfy us that they are legally able to work within the UK.

From time to time we employ the services of employment agencies to source candidates for permanent or fixed term positions, or employment agencies to provide temporary workers. In each instance we have a preferred supplier list for these agencies, and we expect them to adhere to our standards on the prevention of slavery and human trafficking.

We continue to roll out training and awareness materials to all our staff regarding sbe’s anti-slavery policies. In addition, we encourage staff who may have concerns about any aspect of our work including our provisions for anti-slavery and human trafficking, both internally and within our supply chain, to disclose their concerns in accordance with the whistleblowing policy.

Our business and supply chain

We are committed to implementing and enforcing effective systems and controls to seek to ensure that modern slavery is not taking place anywhere in our business or supply chains. We monitor and take a continuous improvement approach to doing this. We aim for greater transparency within our business and supply chain so that we can better understand where the risks lie thus becoming better informed in our decisions to prioritise improvement processes that will prevent our direct or indirect support for any act of Modern Slavery.

Suppliers’ ethical performance will be monitored on an ongoing basis at a frequency determined by the level of risk and vulnerability within their supply chain and we will continue to review the effectiveness of these controls in reducing the risk of unethical practices.

Responsibility for the Policy

This policy, its use and effectiveness are continually monitored internally to ensure that our companies and suppliers comply with our legal and ethical obligations. This includes dealing with any queries about our practices and auditing internal control systems and procedures to ensure they are effective in countering Modern Slavery.

Managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy and the issue of modern slavery in supply chains.

Approval

This statement has been approved by the relevant Boards of Directors of the companies in the sbe group.