Statement under Section 54(1) of the UK Modern Slavery Act 2015 (“MSA”)
for London and Regional Group Hotels Ltd  and their affiliated entities
(together the “L+R Hotels Group” or the ”Group”)

The L+R Hotels Group recognises the importance of respecting human rights as embodied in the International Bill of Human Rights, The UN Guiding Principles on Business and Human Rights, and the United Nations Universal Declaration of Human Rights. We recognise that modern slavery and human trafficking are grave forms of human rights abuse and we will never knowingly trade with companies that have been shown to employ or utilise slavery, servitude, forced and compulsory labour, child labour or who are complicit in human trafficking activities. We are committed to preventing fall kinds of slavery across all business dealings and transactions in which we are involved, regardless of location, and throughout our supply chain. We always strive to work to the highest professional standards and comply with all laws, regulations and rules relevant to our businesses.

About L+R Hotels

The L+R Hotels Group is a global private investment business that owns and manages an extensive hotel portfolio that includes some of the finest branded and independent hotels and resorts in the UK, Continental Europe, the US and the Caribbean. The Group’s net asset value was £715m as at 31 December 2023 with the Group continuing to focus on creating value for investors and communities, building on the strength of its properties and people including employees, guests, partners and investors.

• For more information on the Hotels group, please visit our website at www.landrhotels.com

Policies

The policies of the Group have been developed to ensure high standards of conduct and ethical behaviour in all of our business activities and we expect the same standards from all our contractors, suppliers and other business partners.

We have policies and procedures in place across the Group to protect our employees and their labour rights, including policies around equal opportunities, working hours and pay. Compliance with these policies is monitored by our People and Culture support, as well as Senior Management, and is reviewed on an annual basis with ad-hoc updates made when there are changes in employment law. We aim to be a responsible employer and we are committed to treating our employees with fairness, dignity, and respect. We engage with our employees on a regular basis to help create a safe and diverse work environment where people are comfortable to be themselves. The Group has over 2,800 employees across its operations who perform a wide range of roles including customer facing roles with hotel guests, property management, asset development, finance, ESG, procurement, marketing and risk and compliance. Each hotel has an HR Manager, and formal policies, procedure and approval structures are in place for recruitment. Our recruitment and employment policies are designed to ensure, as far as possible, that the Group is not exposed to the fraudulent recruitment of employees or the exploitation of workers in our hotels.

Employee inductions on joining the Group includes an outline of our expectations for ethical business practices including how to conduct relationships with suppliers and clients. Through internal communications all employees are made aware of the Group’s policies and procedures, including those on health and safety, anti-bullying and harassment, whistleblowing, anti-bribery and corruption and preventing slavery and human trafficking. At individual hotels there are monthly meetings held with staff representatives from each department to ensure that all teams are engaged with and their views considered in the decisions made across our operations. This is in addition to holding physical and virtual staff events at individual hotels to improve staff morale and build teamwork. Through these activities we increase awareness of modern slavery and human trafficking with employees and contractors and ensure that they are equipped to identify, and report suspected instances. Employees are encouraged to discuss the importance of ensuring fair and safe working practices and to report possible signs of modern slavery and trafficking through our whistleblowing channel as set out in the Group Whistleblowing Policy.

We value our supplier partners and the contribution they make in delivering our business objectives including those involved in our purchasing supply chain who provide hotel supplies from linen and stationary to furniture, fixtures, and equipment for use in our hotels as well as those suppliers operating under hotel service agreements, responsible for areas such as maintenance and health & safety. We engage with all our suppliers on a regular basis, holding regular meeting at individual hotels, to build and maintain relationships, including annual supplier events to foster and embed these relationships. Our belief is that this approach increases transparency within our supply chains. We aim to use market-leading suppliers across our product groups and regions, while offering local supply options to our hotels. We have a clear policy for approving suppliers prior to work being commissioned. Our supplier due diligence processes help to identify and address potential risks of modern slavery. We screen our established strategic suppliers to ensure we are only engaging with suppliers who comply with anti-slavery laws and that do not engage in any slavery or human trafficking practices Where cases, or allegations, of forced labour are identified within our supply chain, we investigate any concern thoroughly. There have been no such cases or allegations in FY 2024.

Risk Assessment & Due Diligence Procedures

We will undertake a review of modern slavery risks across the Group towards the end of FY 2025 to identify any significant risks that may have been overlooked. We recognise the potential high risk of modern slavery in the hospitality industry and within our supply chain relating to support services such as cleaning and maintenance amongst others and we will maintain a focus on these areas in our review.

We continue to assess, regularly monitor and mitigate risks relating to slavery and human trafficking on a Group-wide basis, with individual operating companies taking specific actions where appropriate to the level of risk and taking actionable steps to prevent the use of any of the assets we own and/or control for human trafficking and slavery, and to raising awareness concerning such exploitation wherever we do business. No ‘red flags’ associated with modern slavery have been identified.

All staff have identity and age checks undertaken prior to commencing employment and original identity documents are only used for this purpose. Where there is a need to employ temporary workers during peak periods of demand or to address specific short-term skill set shortages and where recruitment agents are used to source such labour, they are regularly vetted, and only reputable agents are engaged. Right to work, age and identity checks are undertaken, and contracts allow such workers to cease employment at will, subject to contractual notices being served.

Training & Looking Ahead

We recognise that modern slavery and human trafficking requires constant commitment and vigilance. Raising awareness of trafficking and modern slavery is key to identifying and helping to prevent modern slavery and human trafficking.

In the statement released last year, we noted that we would endeavour to ensure that all senior managers across the Group and its operating divisions undertake dedicated training relating to preventing modern slavery across our operations and to understanding the red flags associated with modern slavery and the actions they should take should they suspect its existence in our supply chain. To this end, we provided training, in January 2025, via an online compliance training platform from an accredited provider and all senior managers completed the mandatory online training course.

We intend to take the following steps aimed at mitigating modern slavery, forced labour, and human trafficking risks in our operations:

• Continue to monitor potential risk areas in our supply chains on an ongoing basis to ensure that there is no slavery or human trafficking in our supply chains.
• Continue to embed human rights in our policies, governance practices and contracts;
• Undertake an assessment and review of policies periodically.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement for the L+R Hotel group and those joint ventures and funds managed by us, for the financial year ending 31 December 2024. It was approved by the executive board of L + R Hotels Group on 27 June 2025.

Desmond Taljaard

Deputy Chair