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. 

At Treatwell 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.  We have implemented policies, procedures and training to prevent modern slavery taking place anywhere in our own business, in any of the salons we partner with (“Salon Partners”) and in any of our supply chains. We will respond to any concerns raised, investigate fully and take all appropriate action to prevent modern slavery. 

We are also aware of the heightened risk of modern slavery and human trafficking within the hair and beauty industry. We recognise the unique position we are in to be able to raise awareness on the issue and to educate our customers, Salon Partners, their employees and our own employees on how to prevent it from happening anywhere in the industry.

We are 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 have similar processes for their own suppliers.

Due diligence

t is incredibly important for us to only partner with Salon Partners who work to the highest industry standards and are reputable within the hair and beauty space.  We ask all of our Salon Partners to commit to our Partner Terms of Business which set out everything that we expect from them before we allow them on our site, including active measures to prevent modern slavery. 

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 Partner can be listed on Treatwell. This includes (1) in-person salon visits to those offering certain treatments, (2) obtaining insurance documentation and licences where applicable and (3) various other know-your-client and verification checks. Ultimately, we want to ensure that we have reputable Salon Partners 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 a Salon Partner does not operate within the law, that is a material breach of their agreement with us, and we would terminate our partnership with them.  Furthermore, we would report the issue to the Modern Slavery Helpline for them to investigate and take necessary action.

Policies, procedures & training

Our current policies, procedures and training to tackle modern slavery and human trafficking in our supply chains, our Salon Partners and our business include: 

  • Annually inform all employees of Treatwell’s and their own obligations in relation to modern slavery and regularly remind them of the Ethics Hotline, our internal communication channel which employees can use to confidentially detail their concerns if they feel that there is an ethical issue we should be made aware of and investigate. All employees are encouraged to make use of this should they feel they need to and are protected in doing so under our Whistleblowing Policy. We provide guidance to all employees, including when they first join Treatwell and on an ongoing basis, on modern slavery in our industry and the process to go through to ensure concerns are investigated and reported;
  • Annually inform all Salon Partners about Treatwell’s and their own obligations to prevent modern slavery, including reminding them of the guidance we have in place and what they can do if they have their own concerns, either about their own salon or any other salon on our platform; 
  • Provide guidance to Salon Partners to educate them and their employees on modern slavery and provide a procedure to follow to raise any concerns with us and with the official bodies tackling modern slavery;
  • Provide guidance to customers to educate them on what to look for when visiting our salons and how to raise any concerns they may have with us and with the official bodies tackling modern slavery;
  • Report issues to the Modern Slavery Helpline, either directly or by encouraging the individual who has raised the concern to do so, whether a Salon Partner, their employee, a customer or indeed one of our own employees, whilst disclosing that the salon in question is listed on Treatwell and offering our support in helping with the investigations; 
  • Remove any salon which receives any complaint about modern slavery which is corroborated by our own investigation and/or investigations by the Modern Slavery Helpline; and
  • Have registered with the Central Registry for business transparency and published this statement within the Registry. As an authenticated organisation, we are able to access specialist tools and information to help continuously build on our statement whilst supporting wider efforts to tackle modern slavery in the UK.

What next?

These steps won’t eradicate the problem in our industry but we are committed to these measures and to continuously improving upon our approach to modern slavery in order to help combat slavery and human trafficking. We will continue to monitor changes in the law and working practices to assess the impacts these may have on anti-slavery or human trafficking and the measures we can take to prevent it and stop it if we become aware it is happening. 

You can expect more research, louder voices and tougher measures in our fight against modern slavery. 

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 2019. This statement has been approved by Hotspring Venture Limited's board of directors on 30 June 2020.

 

Signature of Director of Hotspring Ventures Limited

Kei Kaji

Chief Executive Officer