It sets out the steps that CC STIM UK Holdco Ltd and its UK holding companies and
subsidiaries as defined in section 1159 of the Companies Act 2006 (“REKOM”) have
undertaken – and is continuing to take – to try to prevent modern slavery or human trafficking
from taking place within our business or supply chain.
We are committed to acting ethically and with integrity in all our business relationships and
this includes taking steps to work towards the removal of slavery and human trafficking from
our business and our supply chain. We are implementing effective systems and controls to
try and make sure that modern slavery does not take place anywhere within our business.
We are a UK based business and we are aware that modern slavery exists even in the UK,
so we cannot be complacent when it comes to these issues.
We are also committed to ensuring there is transparency in our own business and in our
approach to tackling modern slavery throughout our supply chains, consistent with our
disclosure obligations under the Modern Slavery Act 2015 (the “Act”).
REKOM is the UK’s largest operator of late-night bars and clubs, and as of September 2023,
operates approximately 50 premium venues across the country, trading under a number of
concepts including PRYZM, Vinyl, Fiction, ATIK, Bar & Beyond, Steinbeck & Shaw, District,
Proud Mary and Heidi’s. We employ circa 1,600 staff throughout our organisation.
Significant risks in our business
We are aware that the following areas of our supply chain and business are those where
there is a particularly high risk of modern slavery occurring:
1. Temporary or agency staff: We make use of temporary staff at our head office. As
these are not our employees, we are particularly vigilant in checking for signs of
2. Operational and marketing consumables: These items are often manufactured in the
Far East and in areas of Europe where slavery has been identified in the past.
3. Food and drink suppliers: The total supply chain has a far reach covering a large
number of countries including those which have been identified as high risk.
4. Uniform suppliers: Clothing is produced both in the United Kingdom and in the Far
Viewing our supply chain as a whole, the key suppliers that we consider represent a high
risk of modern slavery and/or human trafficking are found in the Far East, Russia, Brazil,
South America, North America, Spain, France, Portugal, Australia and the UK.
We operate a number of internal policies to ensure that we are conducting business in an
ethical and transparent manner. These include:
1. Anti-slavery policy: This policy sets out our expectations of all employees and any
others who work in our business in relation to slavery and human trafficking issues,
including providing guidance on recognising modern slavery, and how employees
should raise any concerns they have. This policy can be found on the internal
document library in the modern slavery section.
2. Whistleblowing policy: This sets out the whistle blowing policy, so that all
employees know that they can raise concerns about how colleagues are being
treated, or practices within our business or supply chain, without fear of reprisals.
This policy can be found on the internal document library in the HR/whistleblowing
section. Our new purpose-built employee App also includes a section where
employees can raise these concerns.
3. Supplier Code of Conduct: This code sets out the minimum standard we expect all
our suppliers to take to work towards eradicating slavery and human trafficking in
their business and supply chain. More details on the Supplier Code of Conduct can
be found in the Supplier policy on the internal document library under the
procurement section. It is also available on our website.
Our supply chain is varied, but our key tier 1 suppliers are those from whom we purchase
our alcoholic and non-alcoholic beverages, food, audio-visual equipment, and consumables.
Our supply chain is based globally and our suppliers themselves source globally.
REKOM operates a supplier policy and maintains a preferred supplier list, and we conduct
due diligence on all suppliers before allowing them to become a preferred supplier. During
the past year we have reviewed our supply chain and obtained statements on compliance
with the Act from all relevant suppliers. Those suppliers that were identified as medium-risk
or high-risk were sent questionnaires to complete to satisfy our audit requirements. The
responses to those questionnaires were reviewed and, where we had concerns, we either
met with suppliers to discuss the matter or the suppliers were asked to provide further
information until we were satisfied with their compliance with the Act.
Our Supplier Code of Conduct forms part of our contract with our suppliers and they are
required to confirm that no part of their business operations contradicts this policy. Suppliers
are also required to obtain confirmation from their own suppliers and sub- contractors that
they comply with the Supplier Code of Conduct.
The Supplier Code of Conduct requires suppliers to confirm the following relating to their
business and supply chain:
1. wages paid to workers are fair;
2. working hours and annual leave comply with national laws and industry
3. no child labour is used;
4. no forced, bonded, compulsory labour or servitude, or any form of human
trafficking is practiced;
5. abuse of workers is not tolerated;
6. a secure, safe and healthy working environment is provided;
7. freedom of association and collective bargaining is respected; and
8. local laws relating to discrimination are complied with.
Looking forward to next year, we will continue working with our suppliers to promote
awareness of slavery and human trafficking.
Approval for this statement
This statement was approved by the Board of Directors on 21-09-2023