OUR POLICIES
Modern Slavery Statement
HIDDENWELL owns and operates luxury hotels, spas, restaurants, and leisure facilities. Our supply chain includes food and beverage suppliers, laundry services, housekeeping products, spa products, uniforms, maintenance contractors, construction contractors, utilities, and agency labour providers. We recognise that although slavery, servitude, forced labour and human traDicking (modern slavery), is illegal it remains a growing issue in the UK. In an increasingly global marketplace, we also recognise that all businesses have a responsibility to understand whether modern slavery and human trafficking is taking place within their businesses and supply chains and this is a responsibility that we take seriously.
Definitions
Modern Slavery – the exploitation of individuals for personal or commercial gain, including slavery, servitude, forced or compulsory labour, and human trafficking. Children under the age of 18 are considered victims of trafficking where they have been recruited, transported, transferred, harboured, or received for the purpose of exploitation, regardless of whether any force, coercion or deception is involved.
Human Trafficking – the recruitment, transportation, transfer, harbouring, or receipt of individuals by means of threat, force, coercion, abduction, fraud, deception, or abuse of vulnerability for the purpose of exploitation, whether within a country or across international borders.
We are committed to making meaningful and long-term improvements to workers' employment and workplace conditions, including, but not limited to, the prevention of forced, bonded, and trafficked labour. We achieve this through our policies, governance arrangements, and due diligence processes, which are supported by our leadership team and embedded throughout the organisation.
We recognise that, whilst the overall risk of modern slavery within our direct operations is low, the hospitality sector presents a number of inherent risks due to the nature of its workforce and supply chains. We therefore remain vigilant in identifying and managing these risks across our business and procurement activities. Areas of increased risk within the hospitality industry include:
• Employing a diverse workforce, including overseas workers, who may be more vulnerable to exploitation if appropriate recruitment and employment practices are not followed.
• Reliance on seasonal, temporary and agency workers to meet fluctuating business demands.
The use of outsourced services, including housekeeping, laundry, cleaning, security, maintenance, and recruitment providers.
A broad and complex supply chain involving numerous suppliers and contractors across different sectors.
The procurement of overseas manufactured goods, including uniforms, furniture, fixtures and fittings, textiles, and spa products.
The sourcing of imported food and beverage products through national and international supply chains.
Construction, refurbishment, and maintenance projects, which can involve multiple contractors and subcontractors operating on our sites.
We recognise that these factors can increase the potential risk of modern slavery and human trafficking. As part of our ongoing commitment, we apply a risk-based approach to supplier due diligence, contractor management, and recruitment practices, supported by appropriate policies, training, and monitoring, to help identify, prevent, and mitigate the risk of modern slavery occurring within our operations and supply chains.
We employ most of our workforce directly; however, we have a small number of independent agents that work for HIDDENWELL. These independent agents can complete tasks such as building works, personal training, or consultation services. All independent agents are contracted directly.
We are committed to responsible recruitment practices across our operations. All employees are subject to appropriate Right to Work checks prior to commencing employment, and we aim to directly employ workers wherever possible. No individual is permitted to commence employment until the required Right to Work checks have been satisfactorily completed.
Where recruitment agencies are used, we undertake appropriate verification and due diligence to ensure they operate ethically and in compliance with applicable legislation. We do not permit the charging of recruitment fees to workers, and we prohibit the retention of passports or other identity documents as a condition of employment. We also ensure that all workers retain the freedom to terminate their employment in accordance with applicable laws and contractual terms, without coercion or penalty.
HIDDENWELL undertakes a risk-based due diligence process to assess whether its suppliers, partners, activities, and countries of operation may present an increased risk of modern slavery or human trafficking. This includes the assessment of suppliers and partners and the application of our Supplier Code of Conduct as part of our onboarding and ongoing compliance requirements.
Roles and Responsibilities
HIDDENWELL has assigned responsibility for the following key areas:
Policies: led by our People team and reviewed or updated annually (e.g., whistleblowing, recruitment, Right to Work checking procedures, etc.)
Staff training: all employees are required to complete mandatory Modern Slavery awareness training as part of their induction. Refresher training is provided where appropriate, and completion rates are monitored by the People Team to ensure compliance. Employees are also made aware of this statement and receive guidance on recognising and reporting the signs of modern slavery and human trafficking.
Statement review: The Group Head of Risk and Compliance is responsible for the review and ongoing updating of this statement.
Supply Chain
We procure goods and services from a range of UK-based suppliers to support the operation of our hotels, spas, and associated facilities. Our supply chain includes, but is not limited to, furniture, fixtures and fittings, food and beverage suppliers, operational supplies, agency labour providers, housekeeping contractors, laundry and linen services, cleaning chemicals, spa and beauty product suppliers, uniforms, maintenance contractors, construction and refurbishment contractors, waste management providers, security services and recruitment agencies. We recognise that certain sectors within our supply chain present a higher risk of modern slavery and human trafficking, and we are committed to undertaking appropriate due diligence to identify, assess and mitigate these risks.
Supply Chain Due Diligence
HIDDENWELL undertakes a risk-based approach to supply chain due diligence to help identify, prevent, and mitigate the risk of modern slavery and human trafficking within our operations and supply chains.
Supply chain due diligence is led by our Procurement Team. As part of our supplier onboarding process, all new suppliers and key partners are required to complete a due diligence process which may include supplier questionnaires covering ethical trading, labour practices, and compliance with modern slavery legislation. Where appropriate, suppliers are required to confirm their compliance with our Supplier Code of Conduct and relevant contractual obligations relating to modern slavery and human trafficking.
We include appropriate contractual provisions within our supplier agreements which require suppliers to comply with applicable laws, uphold minimum labour standards, and notify us of any actual or suspected instances of modern slavery within their operations or supply chains.
Where suppliers are identified as operating in higher-risk sectors or geographies, we may undertake enhanced due diligence measures. This can include country or sector risk assessments, additional documentation requests, and where appropriate, the right to audit or inspect supplier practices.
We will conduct periodic reviews of our suppliers to ensure ongoing compliance with our standards and expectations. Where concerns are identified, we will engage with suppliers to implement corrective action plans. If sufficient improvements are not made, we reserve the right to suspend or terminate the relationship.
Through this approach, we aim to maintain responsible, transparent, and ethical supply chain practices and ensure continuous improvement in our management of modern slavery risks.
Risk and Monitoring Compliance
HIDDENWELL recognises its responsibility to prevent modern slavery and human trafficking throughout its operations and supply chains.
We will continue to monitor suppliers operating within sectors or geographical areas considered to present a higher risk of modern slavery. We will continue to address modern slavery with these suppliers by requesting copies of their policies and procedures and carry out our own audits. We have also included new learning modules for all our teams on Modern Slavery and provide all management with a recruitment training course to attend to ensure strict compliance.
The effectiveness of our approach is monitored by reviewing mandatory employee training completion rates, recruitment compliance checks, supplier due diligence activities, and the review of any concerns raised through our whistleblowing procedures.
Modern Slavery awareness training is mandatory for all employees as part of their induction, and completion rates are monitored by the People Team. During the reporting period covered by this statement, no reports or allegations relating to modern slavery or human trafficking were received through our reporting channels or by the People Team.
Employees, contractors, and suppliers are encouraged to report concerns through our whistleblowing process.
This Modern Slavery Statement relates to the financial year ending 31st December 2025 and has been prepared in accordance with the requirements of the Modern Slavery Act 2015. It is published in accordance with statutory requirements and will be reviewed and updated annually.
HIDDENWELL is committed to continually reviewing and strengthening its approach to preventing modern slavery and human trafficking. We will continue to review our policies, recruitment practices, supplier due diligence processes, and training programmes to ensure they remain effective, proportionate, and aligned with legal requirements and recognised best practice.
Signed on behalf of the Board:
Adrian Pearson - Director
HIDDENWELL Group Limited
Date: 1st July 2026
Overview
This policy applies to all Hiddenwell employees and contractors. It also applies, as far as is reasonably achievable, to our upstream and downstream supply chain through partners, suppliers and third-party contractors.
Our Commitment to Human Rights
Hiddenwell is committed to upholding human rights throughout our operations and supply chain. Hiddenwell recognises our responsibility to respect and protect the human rights of all individuals, including our employees, customers, suppliers, and the communities in which we operate.
This policy outlines our commitment to
Compliance with National Law and International Human Rights Standards: Hiddenwell will comply with all applicable laws and regulations related to human rights, including those in the UK and any other jurisdictions where we operate. Where national law and international human rights standards differ, the higher standard will be followed; where we are in conflict, national law will be adhered to, while seeking ways to respect international human rights to the greatest extent possible.
Respect for International Human Rights Standards: Hiddenwell will respect internationally recognised human rights and principles, as set out in the:
International Bill of Human Rights (consisting of the Universal Declaration of Human Rights (UDHR), International Covenant on Economic, Social and Cultural Rights and International Covenant on Civil and Political Rights.
International Labour Organisation’s (ILO) Declaration on Fundamental Principles and Rights at Work.
The United Nations Guiding Principles on Business and Human Rights.
Due Diligence: Hiddenwell will conduct ongoing due diligence to identify, assess and manage potential human rights risks associated with our operations and supply chain. Potential human rights risks are overseen by the Board of Directors.
Grievance Procedures and Transparency: Hiddenwell have an appropriate grievance mechanism in place for any identified human rights issues and will be transparent about human rights practices and performance.
Hiddenwell does the following:
Work with Employment Lawyers
Work with the leadership team on human rights
Work with supply chain partners
Work with the senior management team and HR department to ensure the implementation and regular review of robust, transparent policies that advance human rights, positively contribute to their promotion, and meet legal human rights requirements.
Stakeholder and Supply Chain Relationships
Hiddenwell expects that our employees, business associates, and any other entities whose actions may have a direct connection to our operations will uphold human rights standards.
Hiddenwell will:
Communicate Expectations: Clearly communicate our human rights expectations to suppliers and other stakeholders, through our Supplier Code of Conduct.
Monitor Performance: Where appropriate, monitor supplier performance and take action to address any concerns.
Support Improvement: Support supplier efforts to improve our human rights practices.
Employment Practices
Hiddenwell is committed to providing a safe, fair and respectful workplace for all employees.
Equal Opportunity: Providing equal opportunities for all employees.
Fair Treatment: Ensuring fair wages, working conditions and treatment of all employees. All employees receive salary reviews.
Anti-Harassment: Prohibiting discrimination and harassment.
Health and Safety: Providing a safe and healthy working environment and complying with all relevant health and safety laws and regulations. We have a Company Health and Safety Policy that employees are required to read and sign.
Respecting Rights: Respecting employee rights to freedom of association.
Anti-Slavery: Preventing and eliminating all forms of modern slavery, forced labour and child labour practices. Our Modern Slavery Statement can be found on the Hiddenwell website.
Transparency and Communication
Hiddenwell recognises the importance of transparency and communication regarding human rights Hiddenwell will:
Stakeholder Engagement: Engage with stakeholders, including employees, suppliers, and communities, to gather feedback and address concerns.
Employees receive access to policies via Harri, a Learning Management System (LMS). Employee engagement with the resources on the platform is tracked to ensure that everyone has read and understood each company policy. Policies are regularly updated by HR, as necessary, and will be signed off by members of the leadership team.
All suppliers receive a copy of our Supplier Code of Conduct that is reviewed and updated, when necessary. All new suppliers undergo a robust screening process to ensure that we are engaging in ethical practices.
Reporting: Report on our human rights performance, including any challenges and progress made through annual impact report.
Training: Provide training to employees on human rights issues and our responsibilities.
Hiddenwell provides all leadership positions with training. The company holds strategy days that discuss new policies or revise existing policies. Conflict resolution and management training occurs once every quarter.
All employees, via Harri, must undergo onboarding and annual training and awareness programmes. This platform ensures that training and awareness session completion rates are measured and employee training is kept up to date.
Grievance Mechanism
Hiddenwell has a grievance mechanism to allow employees, contractors, and other stakeholders to raise human rights concerns. All complaints will be investigated promptly and fairly. Please see Grievance Policy.
Hiddenwell Group has a Designated Safeguarding Lead (DSL) to whom employees can also report grievances to. Each location as a Safeguarding Officer.
At Hiddenwell we are committed to conducting business in an ethical, transparent, and responsible manner. We expect our suppliers to adhere to the highest standards of integrity, sustainability, and fairness. This Supplier Code of Conduct outlines the principles and standards we require our suppliers to uphold to ensure we work together in an ethical and socially responsible manner.
Compliance with Laws and Regulations
We expect our suppliers to abide by all applicable laws and regulations in any jurisdictions in which they operate.
1. Ethical Business Practices
Honesty and Integrity: Suppliers must conduct their business with the highest level of honesty and integrity, ensuring that all interactions and transactions are transparent, fair, and free from bribery, corruption, or unethical practices.
Anti-bribery and Corruption: Suppliers are expected to comply with all applicable anti-bribery and anti-corruption laws, ensuring that no form of bribery, kickbacks, or improper influence is accepted or offered.
Conflicts of Interest: Suppliers should avoid any conflict of interest in their business dealings and disclose any situation where a conflict may arise.
2. Labour and Human Rights
Fair Labour Practices: Suppliers must adhere to all applicable laws regarding working hours, wages, and conditions of employment. No employee should be required to work beyond their legal limits or be paid less than the national minimum wage.
Non-Discrimination: Suppliers should provide a work environment free from discrimination based on race, gender, age, religion, disability, sexual orientation, or any other status protected by law.
Child and Forced Labour: Suppliers must ensure that their operations are free from child labour and forced or compulsory labour. All employees should be hired freely, with their consent and without coercion.
Freedom of Association: Suppliers should respect the right of employees to freely associate, join trade unions, and collectively bargain where applicable, without fear of retaliation.
3. Health and Safety
Safe Working Conditions: Suppliers must provide a safe and healthy work environment for their employees. They should identify and mitigate any health or safety risks, ensuring compliance with relevant health and safety legislation.
Well-being: Suppliers are encouraged to offer health and well-being programmes and promote the mental and physical well-being of their workers.
4. Environmental Responsibility
Environmental Impact: Suppliers must strive to reduce their environmental impact and adopt sustainable practices in their operations. This includes efforts to reduce waste, conserve energy, reduce emissions, and manage resources efficiently within their direct control.
Compliance with Environmental Laws: Suppliers must comply with all applicable environmental laws and regulations in the countries where they operate, including those related to waste disposal, emissions, and the use of hazardous substances.
5. Fair Trading and Transparency
Supply Chain Transparency: Suppliers should ensure transparency in their supply chains and be able to provide information regarding their sourcing practices, including the origin of raw materials.
Accountability: Suppliers should be accountable for their actions and provide the necessary documentation to demonstrate compliance with the requirements outlined in this Code of Conduct.
Anti-Competitive Practices: Suppliers should avoid engaging in anti-competitive practices, including price fixing or market manipulation, and comply with relevant competition laws.
6. Data Privacy and Confidentiality
Protection of Personal Data: Suppliers must protect the personal data of employees, customers, and any other individuals involved in their operations. This includes complying with data protection laws, such as the UK’s Data Protection Act and GDPR.
Confidentiality: Suppliers must maintain the confidentiality of any proprietary or sensitive information provided by Hiddenwell and not disclose or use such information for any unauthorised purpose.
7. Compliance with Laws and Regulations
Legal Compliance: Suppliers must comply with all applicable local, national, and international laws, regulations, and industry standards. This includes compliance with laws relating to employment, environmental protection, health and safety, and business ethics.
Audit and Monitoring: Suppliers agree to allow Hiddenwell or a third-party auditor to conduct reasonable audits and inspections to ensure compliance with the terms of this Code of Conduct.
8. Business Integrity
Respect for Intellectual Property: Suppliers must respect intellectual property rights and refrain from infringing on patents, trademarks, copyrights, and other intellectual property laws.
Responsible Sourcing: Suppliers are expected to adopt responsible sourcing practices, ensuring that raw materials are obtained ethically and that suppliers themselves adhere to fair practices.
9. Continuous Improvement
Ongoing Development: Suppliers should continually work to improve their business practices, implementing improvements related to ethical conduct, labour standards, environmental sustainability, and health and safety.
Collaboration and Feedback:
Suppliers are encouraged to engage in dialogue with Hiddenwell to enhance and develop mutually beneficial relationships that promote shared values and goals.
Acknowledgement and Compliance
By entering into a business relationship with Hiddenwell suppliers agree to adhere to this Supplier Code of Conduct and to uphold the principles set forth herein. Any violation of these standards may result in the termination of the business relationship.
About Hiddenwell
Hiddenwell is a collection of award-winning spa and hotel destinations, dedicated to relaxation, social connection, and sustainability. As a leader in sustainable hospitality, we embrace our responsibility to minimise environmental impact, for our planet, our people, and our guests. At Hiddenwell, sustainability is woven into every experience, ensuring a future that is both luxurious and responsible.
Committed to achieving the highest sustainability standards, our values align with the UN’s Sustainable Development Goals and are committed to carbon neutrality by 2050. At Hiddenwell, our dedication to sustainability goes beyond environmental responsibility. We are committed to upholding the highest ethical standards, ensuring we don’t just meet legal requirements but consistently exceed them in every region we operate.
About this Code
Hiddenwell strives to maintain the highest levels of ethical conduct across all aspects of our business. This Code outlines our core principles and best practices, guiding our commitment to honesty, integrity, and professionalism in our actions and decision-making.
Fairness
Hiddenwell is committed to fairness and equity in all its business dealings. We will always act with honesty and transparency and expect the same from our partners and suppliers.
Individual Responsibility and Accountability
At Hiddenwell, we value individual responsibility and accountability. We empower all employees, board members, and contractors to work freely without undue restriction or sanction, while holding ourselves to the highest ethical and professional standards. We expect the same from everyone associated with Barons Eden.
Environmental Responsibility and Accountability
Hiddenwell is committed to reducing its negative environmental footprint. We continuously strive to lower greenhouse gas emissions from both our operations, and those of our partners and suppliers.
We encourage all employees to consider their environmental impact by being mindful of material and energy use in the workplace, seeking opportunities to conserve, recycle, reduce, or reuse resources.
For further information on how we enact our environmental responsibility, please refer to our ESG Statement.
Compliance with Applicable Laws and Regulations
Hiddenwell adheres to all applicable laws and ethical standards in every territory where we operate. In cases where the ethical standards in one jurisdiction surpass those in another, Hiddenwell applies the higher standards consistently across all regions, ensuring integrity and fairness in every practice.
Conflicts of Interest
Hiddenwell is committed to maintaining transparency and integrity in all business relationships. We require employees, partners, and suppliers to disclose any actual or potential conflicts of interest that may compromise impartiality or create a clash between personal, financial, or professional interests and the interests of Hiddenwell.
Common conflicts include:
Holding external employment or directorships that may affect impartiality.
Having financial or personal ties to Hiddenwell’s suppliers, vendors, or customers.
Engaging in business dealings with close personal connections.
We require employees to submit Declaration of Conflict of Interest forms (GPAI-HR-F002), with high-risk roles completing this annually. Partners and suppliers must also disclose any conflicts within their organisations. Failure to disclose conflicts may raise concerns over fairness, compliance, and ethical conduct.
Equity, Equality, and Parity
Hiddenwell strives for equity and equality within its own operations, ensuring diversity and inclusion across our workforce and trustees. We actively assess diversity at all levels and integrate these considerations into all employment practices. We expect our partners to uphold these same principles.
Financial Reporting
Hiddenwell maintains a policy of financial transparency and expects the same from all its suppliers and partners.
Reporting Violations and Protection from Retaliation
Hiddenwell operates a whistleblowing programme that allows all employees and associates to report breaches or violations of our Code of Ethics. We ensure there will be no discrimination or retaliation against anyone who reports a violation in good faith. Please refer to our Whistleblowing Policy, which can be found in our Employee Handbook.
Social Impact
Hiddenwell is committed to having a positive social impact in all the territories where we operate. We fulfil this pledge by actively supporting local communities, promoting sustainable practices, and ensuring that our operations contribute to the overall well-being of society.
See report here.