Modern Slavery Statement
on behalf of Hotspring Ventures Limited (trading as Treatwell)
Treatwell’s position on slavery
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. We are aware of the heightened risk of modern slavery and human trafficking within the hair and beauty industry and we are committed to implementing policies, systems and controls to ensure that it this is not taking place in our own business, any of the salons we partner with (“Salon Partners”) or in our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains and Salon Partners, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our Salon Partners, third party suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our Salon Partners and any of our third party suppliers will hold their own suppliers to the same high standards.
It is incredibly important for us to only partner with salons who work to the highest industry standards and are reputable within the hair and beauty space. Because we are an online marketplace, we ask all of our Salon Partners to commit to our terms which set out everything that we expect from them before we allow them on site.
All of our Salon Partners warrant to us that, among other things, neither they nor their employees, directors, officers or subcontractors have been investigated for, or convicted of, any offence around slavery or human trafficking, and that they have made all reasonable enquiries on the same. They are also required to maintain policies and procedures to ensure that they comply with their obligations under all anti-slavery laws.
We have a detailed on-boarding process that we undertake before any salon can be listed on Treatwell which includes in-person salon visits to salons offering certain treatments, obtaining insurance documentation, licences where applicable and various other know-your-client and verification checks. Ultimately, we want to ensure that we have reputable salons on site offering the highest standard of service and operating at all times within the law. This extends to the staff that they employ, how they run their business and the importance of anti-slavery and anti-human trafficking measures. If at any time the salon does not operate within the law, that is a material breach of their agreement with us, and we would terminate our partnership with that salon.
As part of our initiative to identify and mitigate risk, we have in place the following systems and policies:
- Identify, assess and monitor potential risk areas in our supply chains and in our Partner Salons
- Mitigate the risk of slavery and human trafficking occurring
- Protect whistleblowers. We have a designated whistleblowing policy to ensure that any whistleblower is protected at all times and their claims investigated in the most effective manner.
- Ethics hotline – we have an ethics hotline where any employee can confidentially detail their concerns if they feel that there is an ethics issue. All employees are reminded of this regularly and are encouraged to make use of this should they feel they need to.
To ensure a high level of understanding of the risk of modern slavery and human trafficking in our supply chains, our Partner Salons and our business, we:
- email our Partner Salons annually reaffirming their obligations in our terms and highlighting key things for them to do;
- Inform all employees of their obligations and remind them of the Ethics hotline; and
- Keep abreast of changes in legislation and any impacts that this may have on anti-slavery or human trafficking measures that we should take.
We are committed to maintaining and improving our training and policies to combat slavery and human trafficking.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2018. This statement has been approved by Hotspring Venture Limited’s board of directors on 29 May 2019.
Signature of Director of Hotspring Ventures Limited
Chief Executive Officer