Slavery and Human Trafficking Statement

This statement is made by Les Ambassadeurs Club (Les A) pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Modern Slavery and Human Trafficking Statement for the financial year ending 31 December 2020.

As a leading high-end casino in London, we understand that we need to lead by example in the way that we do business. At Les A we aim to act fairly, ethically and openly in everything that we do and we have a zero-tolerance approach to any form of slavery, servitude, human trafficking, forced or coerced labour or exploitation. We are committed to preventing modern slavery and human trafficking in our business activities, and to ensuring that our supply chains are free from all forms of slavery and human trafficking. The approach adopted by Les A, forms part of the broader social responsibility and ethical business standards adopted by the Company. As a responsible corporate citizen, we are committed to operating in accordance with the International Bill of Human Rights (comprising the Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights and the International Covenant on Civil and Political Rights).

Our business

Les A is the leading high-end casino in London, located at 5 Hamilton Place in the heart of London’s Mayfair. Les A operates exclusively in the UK but has a diverse international clientele of high net worth individuals.

Our work force

We have approximately 350 staff employed in the UK with only occasional externally contracted staff and no casual labour. We have a comprehensive suite of employee responsibility policies which are relevant to our attempts to ensure that there is no modern slavery in any part of our work force. Our HR policies include a detailed Recruitment Policy (with employee eligibility checks), Grievance Procedure, Equal Opportunities policy and Whistleblowing Policy. We actively encourage employee engagement and representation.

Our supply chains

Our supply chains include the sourcing of high-end food, beverages, entertainment and other services. With regards to modern slavery, our primary focus is on high risk areas of our supply chain, which include, but are not limited to, the manufacture of uniforms, IT hardware and our occasional sub-contracted workers. Additionally, we are focusing on any business in emerging economies and less developed countries. We operate one business at one location and thus our supply chains are limited and our exposure to the risks of modern slavery is low. However, we recognise that there is scope for modern slavery to occur and thus remain vigilant.

Our policies on modern slavery and human trafficking

We are committed to ensuring that modern slavery and human trafficking play no part in our business or supply chains. All our employees are bound by a Code of Conduct which requires them to report any breach or potential breach of legislation and we have a Whistleblowing Policy through which effective reporting of such matters can be reported by staff.

2019/20 Update

There have been no fundamental changes to Les A’s business this year and we have seen very low levels of staff turnover and only minor changes in suppliers. We have continued to be actively engaged with our supply chain throughout the last year in order to satisfy ourselves that we are only contracting with those companies that are engaged in this area and have high ethical standards. There continues to be board level approval for visits to suppliers as necessary, during which procurement personnel are able to assess the supplier and our employees and to assess the risk of modern slavery in that business.

Training

We will communicate this statement to all relevant employees to ensure a high level of understanding of the risks of modern slavery in our business and supply chains. Any suppliers considered at risk will be made aware of this policy and required to demonstrate compliance. All those that have purchasing authority will be given specific training on the risks of Modern Slavery and Human Trafficking.

Looking forward

Due to the low risk rating of the business, our employees and suppliers to the potential for Modern Slavery, we do not have key performance indicators at this time. However, we will assess any instances of non-compliance with our policy on a case-by-case basis. In relation to our own employment practices, we monitor and review any Issues raised through our Whistleblowing Policy In relation to potentially at-risk suppliers, we will only trade with those who comply with this policy or who are taking verifiable steps towards compliance with it.

Approval for this statement

This statement was approved by the Board of Les A on 18th December 2019 and it will be reviewed and updated annually.

ANTI-BRIBERY AND CORRUPTION STATEMENT

Les A has a policy of zero tolerance with respect to Bribery and Corruption. Les A has procedures to prevent bribery, by persons associated with it, that are proportionate to the bribery risks it faces and to the nature, scale and complexity of the company’s activities. They are also clear, practical, accessible, effectively implemented and rigorously enforced.

Approval for this statement

This statement was approved by the Board of Les A on 18th December 2019 and it will be reviewed and updated annually.