Modern Slavery Statement.

01.Introduction

Our position

NWH has a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our business dealings and to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in our own business or in our supply chains.

"Modern slavery" in this statement refers to the offences set out in the Modern Slavery Act 2015: slavery, servitude, forced or compulsory labour, and human trafficking — together with the practices identified in the United Nations' Sustainable Development Goal 8.7.

02.Our organisation

Structure, business and locations

New World Hospitality Limited is an independent UK hotel operator, asset manager and investor, founded in 2014 and headquartered in London. We act on behalf of family offices, private investors and institutional capital across three disciplines:

• Hotel Operations — day-to-day P&L responsibility for hotels operated under management agreement, including branded properties under franchise to Hilton, IHG, Marriott and others.
• Asset Management — strategic oversight on behalf of owners and lenders.
• Investments — acquisition, development and conversion of UK and Irish hotel assets.

As at the date of this statement, NWH operates approximately 20 hotels across the United Kingdom, with around 1,200 keys under management. Our portfolio is geographically diversified from Orkney in the north to the south coast of England.

The group's reported portfolio revenue for the most recent financial year was approximately [£XX million]. NWH directly employs [number] people centrally; in addition, hotels under our operational management collectively employ approximately [number] people.

03.Our supply chain

Where modern-slavery risk could exist

NWH's supply chain breaks down into the following principal categories of supplier:

Hotel operating supplies & services

Goods and services procured for hotels under our operational management — including food & beverage, linen and laundry, cleaning supplies, hotel consumables, and ground-floor services such as housekeeping, maintenance and security where these are outsourced.

Capital projects, FF&E and refurbishment

Construction, fit-out, furniture, fixtures and equipment for refurbishment, conversion and new-build projects, including direct contractors and their sub-contractors.

Professional & corporate services

Lawyers, auditors, banks, IT providers, real-estate advisors and other professional firms with whom we contract directly. We assess this category as low risk for modern slavery offences.

Brand and franchise relationships

Hotel groups under whose brands we operate properties — these are not "suppliers" in the traditional sense, but they are an important part of the broader operating ecosystem and we expect them to maintain their own modern-slavery commitments.

The vast majority of our suppliers are based in the United Kingdom and the European Economic Area. Where we use suppliers based outside these regions — typically for FF&E procurement or specialist trades — we take additional care to verify their modern-slavery compliance.

04.Policies & governance

How we operationalise our position

The following policies sit alongside this statement and govern our approach:

• Modern Slavery and Human Trafficking Policy — sets out the standards expected of NWH employees, contractors and suppliers, and the consequences of non-compliance.
• Whistleblowing Policy — provides a confidential channel for any individual to raise concerns about modern slavery or any other unethical or unlawful conduct.
• Recruitment Policy — ensures that all hires are subject to right-to-work checks and are recruited on terms that prohibit any payment of recruitment fees by the worker, in line with the Employer Pays Principle.
• Supplier Code of Conduct — requires suppliers to confirm their compliance with the Modern Slavery Act 2015 and to flow equivalent obligations down to their own sub-contractors.

Overall responsibility for these policies rests with the Board of NWH. The Finance Director is the executive sponsor for modern-slavery compliance, supported by the Head of Property in respect of group procurement and operational suppliers.

05.Due diligence

Steps we take to identify and mitigate risk

Our due diligence process for modern slavery operates across four stages:

1. Onboarding — new suppliers above a defined contract-value threshold are required to confirm their compliance with the Modern Slavery Act 2015 and (where applicable) to provide a copy of their own modern-slavery statement.
2. Contracting — supplier contracts include modern-slavery warranties and an audit right enabling NWH to verify compliance.
3. Ongoing monitoring — we maintain a register of higher-risk suppliers and review their compliance on a periodic basis. We also encourage operational managers and GMs to escalate any concerns identified at property level.
4. Investigation & remediation — any credible concern is investigated by the Finance Director, with external support where appropriate. Where a supplier is found to be non-compliant, we will work with them to remediate where possible, or terminate the relationship.

06.Risk areas

Where we focus our attention

The hotel industry is widely recognised as one of the higher-risk sectors for modern slavery, particularly in respect of:

• Outsourced housekeeping and cleaning labour — where workers may be employed by sub-contracted agencies and where wage and immigration risks can be elevated.
• Construction and refurbishment — where multi-tier sub-contracting can obscure the labour conditions further down the chain.
• Laundry and linen services — particularly where these are outsourced to commercial laundries with mixed workforces.
• Use of guest-facing accommodation by traffickers — hotels can be used by perpetrators of human trafficking; staff awareness is the principal control here.

We treat each of these areas as a focus for our due-diligence and training activity, reflecting industry guidance from organisations including the Stop Slavery Hotel Industry Network and UK Hospitality.

07.Training & awareness

Building staff capability

To embed our position across the organisation, we provide:

• Awareness briefings for all NWH employees on the indicators of modern slavery and the channels through which concerns can be raised.
• Operational guidance to General Managers and Heads of Department at hotels under our management on identifying signs of trafficking — including unusual booking patterns, signs of distress in guests, and indicators in agency-supplied workers.
• Specific training to procurement and finance staff on the contractual and onboarding controls that operate at NWH's central level.

08.Effectiveness & KPIs

How we measure progress

We measure the effectiveness of our approach through the following indicators:

• Percentage of in-scope suppliers that have signed our Supplier Code of Conduct.
• Number of modern-slavery awareness briefings delivered across the portfolio in the year.
• Number of concerns raised through whistleblowing or operational escalation channels, and the outcome of any subsequent investigation.
• Outcome of any internal or external audit relating to modern-slavery controls.

During the financial year covered by this statement, NWH recorded the following:

• [Insert summary of KPIs for the relevant FY — e.g. number of suppliers signed up, number of briefings delivered, concerns raised. Where the answer is "none" or "zero", state so explicitly — silence reads as evasion.]

09.Approval & signature

Section 54(6) of the Modern Slavery Act

This statement has been approved by the Board of New World Hospitality Limited and is signed by a director of the company in accordance with section 54(6) of the Modern Slavery Act 2015.

It will be reviewed and updated annually, and a fresh statement issued for each financial year.