Cote Restaurants Holdings Group Ltd.’s Modern Slavery Policy Statement

This is Cote Restaurants Holdings Group Ltd.’s third annual Modern Slavery Policy Statement. Since the initial statement in April 2017, we have built on our commitments to identify and eradicate Modern Slavery in our Operations. Further details will be laid out in the following statement.

Organisation structure

Cote Restaurants Group Holdings Ltd. encompasses 3 brands (Cote Restaurants Ltd, Jackson + Rye Ltd and Limeyard Ltd) operating over 100 locations across the United Kingdom.

We operate with a turnover in excess of £150m and employ over 3,400 people across our restaurants and Operations team.

Our supply chains include the provision of food and drink products, various support goods and services, such as building maintenance and technology suppliers. In excess of 140 suppliers are used to enable us to provide meals and drinks to our guests in our businesses.

Cote Restaurants Holdings Group Ltd. statement on slavery and human trafficking

We have a zero-tolerance approach to any form of mistreatment of people and we are committed to operating and conduct of its business in such a way that human rights are respected and protected. We will not permit or condone any form of slavery, servitude, forced or compulsory labour or human trafficking.

We recognise that our business has a role to play in managing this issue and we are firmly committed to working to identify and eradicate modern slavery practices from our operations and our supply chains, to the extent that they exist.

Recruitment and supply chains

Recruitment

We operate a robust recruitment and employment process. We embrace principles supportive of equal treatment without discrimination and with the protection of employment law for all staff.

They are broadly based on principles developed by the United Nations and Institute for Human Rights and Business regarding migrant workers. However, we have chosen to extend relevant principles to all our staff.

We treat all staff equally; without discrimination and with respect for their human rights. All staff enjoy the protection of relevant UK law in respect of their employment.

Cote Restaurants Ltd. selects approved recruitment partners for certain types of jobs. Approved partners are reviewed on a regular basis.

Supply chain

We recognise that our biggest exposure to Modern Slavery is in our product supply chains. As such, we also encourage our suppliers to endorse such principles to demonstrate their opposition to human trafficking and modern slavery.

We have introduced a Code of Conduct for all our suppliers. This Code of Conduct ensure that our suppliers are aware of our commitment to identify and eradicate any form of Modern Slavery in our supply chain, identify and eradicate any form of Modern Slavery in their own supply chain and the need for each supplier to implement a system of training for their employees, suppliers and sub-contractors to ensure compliance with our Modern Slavery Policy.

As of April 2019, this Code of Conduct had been distributed to a total of 91 existing suppliers in our Food & Beverage (F&B), Learning & Development (L&D) and Property department. 88 suppliers have agreed to this Code of Conduct (fig. 1).

Fig. 1: Code of conduct agreement

The 3 suppliers who have not signed this Code of Conduct have provided the Company with a copy of their own Code of Conduct, Ethical Trading and Modern Slavery policy and we are satisfied that all aspects of our Code of Conduct are covered.

Due diligence processes for slavery and human trafficking

We have a policy in place to protect whistle blowers who highlight to us any risk of slavery or human trafficking within our business.

We will continue to communicate our expectations to team members, suppliers and contractors with regards to human rights and modern slavery.

Training

Since the publication of our initial statement in April 2017, we have implemented an online training and communication tool available to all team members, managers and members of our Operations team. This training tool provides us with the opportunity to implement Anti-bribery, Equality and Diversity and Modern Slavery training for managers at all levels.

All managers are asked to complete this course within their first 12 weeks of employment and regular reporting on completion rates is distributed with Senior Managers.

Further steps

Cote Restaurants Holdings Group Ltd. will be reviewing and updating its Modern Slavery Policy and policy statement annually. We will build on our commitments to further map out our supplier chain, ensure all our suppliers have committed to the principles laid out in our Code of Conduct and ensure that training is delivered to all our senior managers in the business.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.

Name: Strahan Wilson
Role: Chief Financial Officer

Issued: 29th of April 2019
Next policy review due: 28th of April 2020