Modern Slavery Act Statement 2026
About Sutton 1079
Sutton 1079 Limited manages a portfolio of hotels, property and rural estates. The hotels include the Francis Hotel in Bath, the Castle Hotel in Windsor and The Athenaeum Hotel & Residences in Mayfair, London.
Our commitment
We are committed to conducting our business ethically, responsibly and with integrity. We take a zero-tolerance approach to all forms of modern slavery and human rights abuse, including human trafficking, slavery, servitude, forced or compulsory labour, child labour and the exploitation of vulnerable individuals.
We recognise our responsibility to respect and uphold human rights. We are committed to preventing modern slavery within our own operations and, where reasonably practicable, throughout our supply chains.
Our business and supply chains
We employ colleagues in a range of professional, operational and customer-facing roles across our hospitality, property and rural estate businesses.
Our supply chains include suppliers of goods and services across recruitment, facilities management, construction, professional services, food and beverage, technology, maintenance, housekeeping and other operational support services.
Modern slavery risks can arise within supply chains. We expect our suppliers and business partners to operate ethically and comply with all applicable employment and human rights laws.
Policies and governance
Our policies and governance arrangements support our commitment to preventing modern slavery by promoting ethical behaviour and fair treatment. They include:
• Recruitment and Employment Guidelines
• Equality, Diversity and Inclusion Policy
• Whistleblowing (Speak Up) Policy
• Disciplinary and Grievance Procedures
• Supplier standards and procurement expectations, where applicable
Together, these arrangements encourage colleagues to raise concerns without fear of retaliation and support a culture of openness, integrity and accountability.
Employment and procurement practices
We seek to minimise the risk of modern slavery through appropriate employment and procurement practices. These include:
• Recruiting employees through fair, transparent and lawful processes
• Verifying an individual's right to work in the UK
• Providing all employees with written terms and conditions of employment
• Paying employees fairly and in accordance with applicable legislation, including the National Minimum Wage and National Living Wage
• Undertaking appropriate checks on suppliers where considered proportionate to the level of risk
• Encouraging suppliers and contractors to demonstrate compliance with relevant legislation and ethical employment practices
Risk assessment and management
We assess the overall risk within our direct operations to be low. This assessment reflects our commitment to fair employment practices, compliance with employment legislation, appropriate oversight and governance, and the ethical standards we expect from those who work for and with us.
However, modern slavery risks can arise in sectors in which we operate, such as hospitality, agriculture and construction, and within certain areas of our supply chains.
We manage these risks by:
• Promoting ethical recruitment practices
• Monitoring employment practices within our business
• Maintaining effective reporting mechanisms through our Speak Up process
• Considering modern slavery risks as part of supplier engagement and procurement activities, where appropriate
• Reviewing our policies and controls periodically to check that they remain effective
Reviewing our effectiveness
We continually review the effectiveness of our approach to preventing modern slavery. Indicators may include:
• No substantiated incidents of modern slavery identified within our operations
• Completion of right-to-work and employment verification checks for all employees
• Appropriate action taken where concerns are raised through internal reporting channels
• Periodic review of relevant policies and governance arrangements
• Ongoing consideration of modern slavery risks during supplier engagement and contract management, where appropriate
These measures help us assess whether our controls remain effective and proportionate to the size and nature of our business.
Training and awareness
Awareness is essential to preventing modern slavery. We provide managers and relevant employees with guidance and information to help them:
• Understand what modern slavery and human trafficking are
• Recognise potential indicators of exploitation
• Understand their responsibilities
• Know how to report concerns through appropriate internal channels
We will continue to review our approach to training and awareness as our business develops.
Further steps
Sutton 1079 Limited is committed to continually strengthening its approach to preventing modern slavery. We will review this statement annually and continue to assess opportunities to enhance our policies, procedures and due diligence processes so they remain effective, proportionate and aligned with evolving legislation and best practice.
This statement has been approved by Sutton 1079 Limited’s board of directors, which will review and update it annually.
Updated 15th September 2026.
