Legal

MODERN SLAVERY ACT TRANSPARENCY STATEMENT

INTRODUCTION

This is the Modern Slavery Transparency Statement of Ralph Trustees Limited (“RTL”) for the financial year ending 29th April 2018. This statement is made pursuant to s.54(1) of the Modern Slavery Act 2015.

The Modern Slavery Act 2015 creates offences in respect of slavery, servitude, forced or compulsory labour and human trafficking (“Modern Slavery”). RTL are committed to combatting all forms of Modern Slavery.

POLICIES AND PROCEDURES

RTL have existing policies and procedures which assist in combatting Modern Slavery including: checks and verification in respect of migrant workers; core values encompassing open two-way communication that encourages reports from staff of unethical conduct; and a central register of recruitment agents and supplier contracts.

RTL has also recently taken the following steps to further enhance its policies and procedures:

• A Modern Slavery Policy has been put in place
• Suppliers and recruitment agencies have been issued with a copy of the Modern Slavery Policy

In the coming months, RTL intends to take additional steps including:

• Expanding due diligence on subcontractors and suppliers
• Modern Slavery training across the wider group

GENDER PAY NARRATIVE

Mandatory Gender Pay Gap reporting applies to all private and voluntary sector employers in England, Wales and Scotland who have at least 250 employees as of 5th April 2017. Those organisations are required to publicly report their gender pay gap metrics on the government-sponsored website with the aim of eliminating the gender pay gap.

Ralph Trustees Ltd is a family-owned group of luxury hotels and apartments located in and around central London. Each of our establishments has its own individualism and its own sense of style and all are operated by people with a genuine passion for relaxed luxury service.

Over the past few years, we have placed emphasis on driving equality of pay within our business, and we can report that as of 5 April 2017, our mean gender pay gap stands at 9.2%, favouring males. This is well below the average gender pay gap reported by the Office for National Statistics which stands at 18.4% for 2017. Furthermore, there is 0% gap between males and females in terms of median pay.

Where we will be focusing extra attention now is on our mean gender bonus gap which stands at 33.2%, favouring males. Having undertaken a review of this, we are satisfied that there is no underlying issue here and the number is distorted by the fact that there are a relatively small number of people who receive bonuses and therefore in any one year any exceptional or one-off payments can result in a significant distortion of the percentage figure.

We continue our commitment to driving equal pay across our business, not only through our reward strategy but also through our approach to recruiting, training, developing, coaching, promoting and supporting our teams.