Modern Slavery Transparency Statement



  • Slavery and Human Trafficking Statement - Account year end April 2022


    Introduction

    This modern slavery and transparency statement is published by Diamond Resorts (Holdings) Limited and Diamond Resorts (Europe) Limited (together “Diamond”), in accordance with the UK Modern Slavery Act 2015 (the “Act”) for the period ending 31 December 2021.


    Our business

    Diamond Resorts (Holdings) Limited is the parent company of the Diamond Resorts® group of companies in Europe and Diamond Resorts (Europe) Limited is the main European operating company for the group.

    In August 2021, following an acquisition and merger of Diamond Resorts International Inc., Diamond  became a subsidiary of Hilton Grand Vacations Inc. (‘HGV’) (a company incorporated in Florida, United States of America) and the group is now one of the largest vacation ownership companies in the world.

    Diamond manages various timeshare clubs across Europe and owns/manages resorts in amazing holiday destinations across Europe. As one of the world’s leading vacation ownership companies, Diamond constantly aims to exceed expectations  with its high quality resorts and incomparable hospitality.

    Diamond remains fully committed to conducting its business affairs fairly and in an ethical  manner, and has implemented various policies and procedures to prevent all forms of modern slavery within its organisation and its supply chains. Previous Modern Slavery Statements detailing the steps taken are posted on this site and can be reviewed,


    Our supply chains

    Significant steps were undertaken during the course of the period covering the last Modern Slavery Statement, to introduce supplier risk assessments to enable the business to better understand and manage its supply chains and our supplier risk audits remain an active and useful tool in combatting modern slavery. 


    Our policies

    The Coronavirus pandemic has had a significant impact on the business, for better and for worse. One impact has been the ability to allow all corporate based staff members to operate from home (a feat that previously would not have been considered possible). To operate homeworking effectively,  new homeworking policies were introduced which included a requirement to conduct employee risk assessments  in order to safeguard their health and safety, including the assurance that they were not falling subject to any modern slavery practices (such as excessive working hours).

    Furthermore, the re-opening of our resorts has allowed the business to evaluate its best practices for tackling modern slavery compliance. Alongside the supply chain risk assessments introduced last year, the business has now taken  steps to introduce on-site risk assessments which aim to prevent modern slavery issues “on the ground” should they  arise, by conducting visual inspections of sites, and conducting interviews with key staff alongside random interview selections of staff members on site.


    Our recruitment

    During the recruitment process the business always requires sight of a candidates ‘right to work’ documentation to ensure that they are not in any way being subjected to any oppressive practices. As a matter of note, the business never retains original “right to work” documentation and will only take copies of such documentation when a candidate is offered employment with the business.

    The business has also taken steps toward introducing a recruitment fraud warning on its career site to help potential recruits identify the potential signs of recruitment fraud. Recruitment fraud being the practice of rogue operators claiming to be representatives of Diamond or HGV offering fake job opportunities in exchange for money or personal data.


    Our future

    As Diamond and HGV continue to come together as one entity over the forthcoming years, our policies and procedures regarding modern slavery will continue to develop. Processes will be merged, fine-tuned and honed to ensure they go beyond minimum expectations and seek to become best in class, as is the ethos of both Diamond and HGV.


    Statement approval

    This statement has been reviewed, approved and signed by our statutory director in the UK.

    Susan Crook

    Date 27 March 2022
    Susan Crook
    Director


    View a PDF version of the 2022 Slavery and Human Trafficking Statement.



  • Slavery and Human Trafficking Statement


    Introduction

    This modern slavery and transparency statement is published by Diamond Resorts (Holdings) Limited and Diamond Resorts (Europe) Limited (together “Diamond”), in accordance with the UK Modern Slavery Act 2015 (the “Act”) for the period ending 31 December 2020.

    Diamond has always had and maintains a zero tolerance approach to slavery and human trafficking and is committed to understanding the risks so that we can strive toward ensuring that no modern slavery exists in our business and in our supply chains. Diamond is aware of the enhanced risks of modern slavery and human trafficking occurring due to the industry in which Diamond operates and continues to act accordingly. However, Diamond does not operate resorts in countries which are deemed to be “not free” or “partially free” according to the Freedom House website, and where possible seeks to co-ordinate with local suppliers to ensure the risk of modern slavery remains minimal.

    Diamond has reviewed in detail the report “Beyond Compliance in the Hotel Sector: A Review of UK Modern Slavery Act Statements” 2019 which provided a broad and comprehensive review of the hotel industry work toward complying with the modern slavery obligations. Diamond has also taken a keen interest in the UK government’s report and review of the Act. Diamond awaits, and is well prepared for, any forthcoming changes to the Act that the UK government intends on making as a result of this review.

    2020 has undoubtedly been a challenging year for the tourism industry, but such challenges have not prevented Diamond continuing its high standards in ensuring slavery does not exist in any form in our business.


    Our business

    Diamond Resorts (Holdings) Limited is the parent company of the Diamond Resorts® group of companies in Europe and Diamond Resorts (Europe) Limited is the main European operating company for the group. Diamond manages various timeshare clubs across Europe and owns/manages resorts in amazing holiday destinations across Europe.

    As part of one of the world’s leading vacation ownership companies, Diamond aims to exceed expectations consistently with our high quality resorts and Incomparable hospitality. Diamond is committed to conducting our business affairs fairly and in an ethical and proper manner.

    There has been no significant change to our business operations in the year since publishing our previous Modern Slavery Transparency statement, save for the implications of the Coronavirus pandemic.


    Our supply chains

    Diamond continues to operate with a network of trusted and established suppliers, which service our resorts across the UK and Europe as well as our corporate offices. Our suppliers range from providers of cleaning and laundry services through to providers of office stationary. We do also use a number of approved employment agencies for our recruitment at our resorts and occasionally for our corporate offices.

    Our suppliers vary in size from sole traders through to PLCs. Inevitably the larger the supplier, the more likely it is that they will be reliant upon their own supply chain. To that extent, we will seek to ensure that where we utilise suppliers, who are regulated by the Act, that they have appropriate modern slavery compliance in their own supply chain.

    2020 has seen the introduction of a new initiative launched by Diamond to audit suppliers to ensure no modern slavery exists in their business. This is a new roll out of a project, and Diamond expects the need to iron out potential issues that may arise in the development of such a large scale project over the course of 2021. The legal team has worked with the purchasing and human resources department in the roll out of the initiative. We anticipate that by the end of 2021 and moving into 2022 this audit process will be fully operational.

    Further, Diamond has conducted its first annual internal modern slavery risk assessment, which Diamond will continue to develop over the coming years.


    Our policies

    We have updated various internal policies within Diamond to ensure our continued compliance with the Act. Diamond is also aware of the forthcoming ED directive relating to whistleblowing. Whilst Diamond already has a substantive global whistleblowing policy, a review is currently being undertaken in anticipation of that directive.


    Our recruitment

    Diamond is aware of the importance of having an ethical recruitment policy in place to seek to prevent people exploiting or fraudulently using Diamond and the reputation of Diamond to procure recruitment fees from vulnerable individuals.

    Diamond’s recruitment processes in the UK are strictly managed by our dedicated HR team. This year has seen the introduction of an approved recruiter list, where agencies are only used where they can confirm they abide by the Act or are able to confirm compliance with our Labour code of conduct. The list requires that Diamond actively review each recruiter on either an annual/bi-annual basis to monitor continued compliance.


    Our future

    The tourism industry will seek to reboot itself during the year of 2021, and it is hoped that Diamond will be a strong industry leader in that reboot. Whilst inevitably there will be significant focus on ensuring our resorts remain “Covid safe”, Diamond will not let its focus and energies on modern slavery dip. Our legal team retains a dedicated function to dealing with modern slavery issues and will continue to liaise with departments across the business to ensure that existing practices continue to be adhered to and that, where appropriate and relevant to the business, new procedures will be brought in.

    Diamond will continue to work on new initiatives and policies that protect our team members, our supply chain and our valued members and guests.


    Statement approval

    This statement has been reviewed, approved and signed by our statutory director.

    Susan Crook

    Date 15 March 2021
    Susan Crook
    Director


    View a PDF version of the 2021 Slavery and Human Trafficking Statement.



  • Modern Slavery Transparency Statement - 2020


    Introduction

    This modern slavery and transparency statement is published by Diamond Resorts (Holdings) Limited and Diamond Resorts (Europe) Limited (together “Diamond”), in accordance with the UK Modern Slavery Act 2015 (the “Act”) for the period ending 31 December 2019.

    Diamond has always had and maintains a zero tolerance approach to slavery and human trafficking and is committed to understanding the risks so that we can strive toward ensuring that no modern slavery exists in our business and in our supply chains. Diamond is aware of the enhanced risks of modern slavery and human trafficking occurring due to the industry in which Diamond operates and continues to act accordingly.


    Our business

    Diamond Resorts (Holdings) Limited is the parent company of the Diamond Resorts® group of companies in Europe and Diamond Resorts (Europe) Limited is the main European operating company for the group. Diamond manages various timeshare clubs across Europe and owns/manages resorts in amazing holiday destinations across Europe.

    As part of one of the world’s leading vacation ownership companies, we aim to exceed expectations consistently with our high quality resorts and incomparable hospitality. We are committed to conducting our business affairs fairly and in an ethical and proper manner.


    Our supply chains

    Diamond has a network of trusted and established suppliers, which service our resorts across the UK and Europe as well as our corporate offices. Our suppliers range from providers of cleaning and laundry services through to providers of office stationary. We do also use a small number of approved employment agencies for our recruitment at our resorts and occasionally for our corporate offices.

    Our suppliers vary in size from sole traders through to PLCs. Inevitably the larger the supplier, the more likely it is that they will be reliant upon their own supply chain. To that extent, we will seek to ensure that where we utilise suppliers, who are regulated by the Act, that they have appropriate modern slavery compliance in their own supply chain.

    In the event that we contract with a new supplier to provides services to Diamond we will ensure that all contracts contain appropriate modern slavery compliance clauses, even with suppliers that would not necessarily be caught by the Act. If a supplier refuses to accept these clauses, Diamond would not proceed in a relationship with the supplier.


    Our policies

    We have adopted and updated various internal policies within Diamond to ensure our continued compliance with the Act. In the preceding 12 months, we have introduced two new policies:

    • General recruitment policy; and
    • Anti-slavery and ethical recruitment policy.

    We have also significantly updated our whistleblowing policy which encourages stakeholders within Diamond to report any anti-slavery or human trafficking violations without fear of retribution or retaliation. Diamond takes all reports of slavery however so arising extremely seriously and all reports are and will be investigated fully.


    Our recruitment

    Diamond is aware of the importance of having an ethical recruitment policy in place to seek to prevent people exploiting or fraudulently using Diamond and the reputation of Diamond to procure recruitment fees from vulnerable individuals.

    Diamond does not require payment of fees to be considered for any role within the company and only accept applications for employment via approved employment agencies or via our own dedicated internal recruitment efforts, which are strictly managed by our Human Resources department.

    Our implementation of our ethical recruitment policy seeks to highlight this point and provides guidance on the issue to all of Diamond’s European employees.


    Our future

    Diamond is aware of the potential changes to the Act following the public consultation on transparency in supply chains conducted in 2019. Diamond has considered the results of the consultation in detail, and now awaits official guidance and updated legislation from the UK government.

    In 2020, we will look to roll out interactive training programmes across Europe to ensure our continued compliance with the Act and we shall continue to identify ways in which Diamond can meet the challenges posed by human trafficking and modern slavery in the hotel and tourism industry.

    Our policies will be kept under continual review and updated as and when is necessary.


    Statement approval

    This statement has been reviewed, approved and signed by our statutory director in the UK.

    Susan Crook

    Susan Crook - European General Counsel
    Vice President of Legal Services


    View a PDF version of the 2020 Modern Slavery Transparency Statement.



  • Modern Slavery Transparency Statement - 2019


    This modern slavery and transparency statement is published by Diamond Resorts (Holdings) Limited and Diamond Resorts (Europe) Limited (together “Diamond”), in accordance with the UK Modern Slavery Act 2015 for the period ending 31 December 2018.

    Diamond Resorts (Holdings) Limited is the parent company of the Diamond Resorts® group of companies in Europe and Diamond Resorts (Europe) Limited is the main European operating company for the group. Diamond manages various timeshare clubs across Europe and owns/ manages resorts in amazing holiday destinations across Europe.

    As part of one of the world’s leading vacation ownership companies, we aim to exceed expectations consistently with our high quality resorts and incomparable hospitality. We are committed to conducting our business affairs fairly and in an ethical and proper manner.

    We require the highest possible standards of ethical and business conduct of our team members in the performance of their corporate responsibilities and all of our staff are obliged to undertake yearly training in ethical business practices.

    We condemn modern slavery and human trafficking in all of its forms and are committed to working to ensure that no such activity takes place within our sphere of influence.

    We engage most team members directly and ensure that the appropriate checks are carried out on our directly employed staff in accordance with applicable laws in the countries in which we operate. Where we use agency workers, relationships are managed by our HR teams who are supported by our own legal function as well as external specialists.

    At our resorts, we enjoy many close relationships with our smaller suppliers and providers of services who are often personally known to our resort managers and local to the resort. Often, such relationships have endured for many years. Larger projects are sourced centrally using the expertise of our purchasing and legal teams.

    In the last financial year, we included appropriate contractual terms in our supply contracts to facilitate greater transparency and to mandate ethical behaviours in their working and sourcing practices. We also developed and introduced due diligence measures relating to ethical sourcing as part of the procurement process for certain spend categories.

    We look forward to developing policy further in this area, to working more closely with our key suppliers and to training our team members to raise awareness of potential issues within our business and industry.

    Signed:  

    Susan Crook

    Dated: 4 April 2019

    SUSAN CROOK
    Vice President of Legal Services and European General Counsel

    Approved by the Board of Directors of Diamond Resorts (Holdings) Limited and Diamond Resorts (Europe) Limited on 4 April 2019


    View a PDF version of the 2019 Modern Slavery Transparency Statement.



  • Modern Slavery Transparency Statement - 2018


    This modern slavery and transparency statement is published by Diamond Resorts (Europe) Limited (Diamond), in accordance with the UK Modern Slavery Act 2015 for the period ending 31 December 2017.

    Diamond is the main European operating company of the Diamond Resorts International® group of companies. We manage various timeshare clubs across Europe and own/ manage resorts in amazing holiday destinations across Europe.

    As part of one of the world’s leading vacation ownership companies, we aim to exceed expectations consistently with our high quality resorts and incomparable hospitality. We are committed to conducting our business affairs fairly and in an ethical and proper manner.

    We require the highest possible standards of ethical and business conduct of our team members in the performance of their corporate responsibilities and all of our team members are obliged to undertake yearly training in ethical business practices.

    We condemn modern slavery and human trafficking in all of its forms and are committed to working to ensure that no such activity takes place within our sphere of influence.

    We engage most team members directly and ensure that the appropriate checks are carried out on our directly employed team members in accordance with applicable laws in the countries in which we operate. Where we use agency workers, relationships are managed by our HR teams who are supported by our own legal function as well as external specialists.

    At our resorts, we enjoy many close relationships with our smaller suppliers and providers of services who are often personally known to our resort managers and local to the resort. Often, such relationships have endured for many years. Larger projects are sourced centrally using the expertise of our purchasing and legal teams.

    In the last financial year, we included appropriate contractual terms in our supply contracts to facilitate greater transparency and to mandate ethical practical in their working and sourcing practices. We also developed and introduced due diligence measures relating to ethical sourcing as part of the procurement process for certain spend categories.

    We look forward to developing policy further in this area, to working more closely with our key suppliers and to training our team members to raise awareness of potential issues within our business and industry.

    Signed on behalf of:

    Susan Crook

    Diamond Resorts (Europe) Limited



  • Modern Slavery Transparency Statement - 2017


    This modern slavery and transparency statement is published by Diamond Resorts (Europe) Limited (Diamond), in accordance with the UK Modern Slavery Act 2015 for the period ending 31 December 2016.

    Diamond is the main European operating company of the Diamond Resorts International® group of companies. We manage various timeshare clubs across Europe and own/ manage resorts in amazing holiday destinations across Europe.

    As part of one of the world’s leading vacation ownership companies, we aim to exceed expectations consistently with our high quality resorts and incomparable hospitality. We are committed to conducting our business affairs fairly and in an ethical and proper manner.

    We require the highest possible standards of ethical and business conduct of our team members in the performance of their corporate responsibilities and all of our team members are obliged to undertake yearly training in ethical business practices.

    We condemn modern slavery and human trafficking in all of its forms and are committed to working to ensure that no such activity takes place within our sphere of influence.

    We engage most team members directly and ensure that the appropriate checks are carried out on our directly employed team members in accordance with applicable laws in the countries in which we operate. Where we use agency workers, relationships are managed by our HR teams who are supported by our own legal function as well as external specialists.

    At our resorts, we enjoy many close relationships with our smaller suppliers and providers of services who are often personally known to our resort managers and local to the resort. Often, such relationships have endured for many years. Larger projects are sourced centrally using the expertise of our purchasing and legal teams.

    In the last financial year, we enjoyed membership of the International Tourism Partnership, which, by facilitating collaboration across the tourism sector, has developed the Industry Position Statement on Human Trafficking. Access to this group and the information it provides assists us with our own policy development and risk assessment activities.

    We also looked at our business and supply chains with a view to identifying any potential areas of risk. We reviewed vendors and services providers, and carried out related due diligence activities. We renegotiated contracts with existing service providers to facilitate greater transparency and to mandate ethical practices in their working and sourcing practices and (to the same end) reviewed our contractual standard documentation with new suppliers and service providers.

    We look forward to developing policy further in this area, to working more closely with our key suppliers and to training our team members to raise awareness of potential issues within our business and industry.

    Signed on behalf of:

    Susan Crook

    Diamond Resorts (Europe) Limited