'...an existing compliance programme comprising policies, procedures and requirements for employees, suppliers and hotels in relation to human rights, ethical practices and modern slavery. This includes robust checks and verification in respect of migrant workers; a whistleblowing policy to encourage reports from staff of unethical conduct; and a central register of recruitment agents and supplier contracts.'

'Implementing an Anti-Slavery Policy:

Issuing our Anti-Slavery Policy to our suppliers and recruitment agencies
Taking external legal advice on the application of the Modern Slavery Act 2015 to our business
Communicating our senior management team's strong support for the aims of the Modern Slavery Act 2015 and our zero tolerance approach to slavery and human trafficking
Conducting a risk assessment of our business and our supply chains (as detailed below)
Identifying Key Performance Indicators against which to assess our progress in managing the risks of slavery and human trafficking in our business and our supply chains'

'We endeavour to conduct regular Risk Assessments of our supply chains. Where we identify suppliers to be "at risk" of slavery and human trafficking we will seek compliance assurances from them; exercise right to terminate early for failure to comply with applicable laws and our Anti Slavery Policy etc'

Policies only apply to suppliers, there is no mention of enforcement beyond the direct tier 1.