MODERN SLAVERY

This is the modern slavery statement of Interval Group. In this document, "Interval", "we", "our", or "us" refer to Interval Group.

Introduction

Pursuant to section 54(1) of the UK Modern Slavery Act 2015 (the “Act”), we are not required to publish an annual modern slavery statement. However, we have chosen to publish details on our approach to preventing modern slavery, as we consider this issue to be of the utmost importance in building a better world.

Our organisational structure
Interval Group refers to the global network of companies that operate under the Interval brand. We provide high quality professional services to solve complex problems. Our wide range of services includes management consulting, programme delivery, technology transformation, digital, PR, training and more.

The firm has two managing partners and access to over 1,000 professionals operating on a contractor basis worldwide, with a particular focus on the EU and UK markets. All partners, employees and contractors share the commitment to building a better working world. Our partners, employees and contractors comprise our client facing and support teams.

Our commitment
Interval strives to make a real difference, which includes conducting our business to the highest possible ethical standards. As part of this commitment, we will not tolerate any form of human rights abuse, including modern slavery or human trafficking, in any part of our business.

The firm is committed to ensuring modern slavery plays no part in its business or supply chains. To satisfy this commitment, we undertake a range of different steps and continue to strive to achieve the highest legal, ethical, environmental and professional standards within our own business and supply chains, making sure that all stakeholders (including employees, contractors, partners and suppliers) are working together to eradicate modern slavery and human trafficking. In relation to our supply chain, we are focussed on working with long-term, strategic partners who demonstrate the same commitment to their people to ensure modern slavery plays no part in their or our business.

Our supply chain
Interval believes that our supply chain is the biggest risk area where modern slavery issues may arise as we work with many different suppliers each year, providing us with a large range of goods from stationary to laptops and providing us with various services from catering to accounting. We use a variety of methods which allow us to undertake due diligence on each of our suppliers and ensure that we have appropriate policies and contractual terms in place to ensure that our suppliers understand the standards that we require of them. To the extent that our suppliers do not adhere to our standards, there can be material consequences, including the termination of our relationship with them.

Our supply chain management
We pay great attention to the appointment of new suppliers. Interval's leadership team (supported by others, including legal and risk advisory teams) is involved in performing due diligence on potential suppliers, to ensure we work with organisations who share our commitment to the highest possible business and ethical standards. This puts us in the position to make informed decisions about who we want to work with. Where we are satisfied that it is a supplier that we want to engage with, we then negotiate appropriate terms with them (adherence to local laws and regulations regarding modern slavery is a non-negotiable item for us). Our supply chain generally falls into the following categories of supply:

Travel, Meeting & Events and Brand, Marketing and Communications Procurement, which spans all forms of business travel and subsistence, meeting arrangements and business events, advertising and public relations;
Real Estate and Workplace Services Procurement, including management of offices and operating expenses, facilities management and office furnishings;
Technology Sourcing and External Content, which includes computer and communications equipment, IT services and development; and
Talent Procurement, including talent acquisition, recruitment screening, employment benefits and learning and development.

We continually evaluate how to identify and address risks in our supply chain, including those related to modern slavery and human trafficking.

Our due diligence
Interval requests all suppliers to register their details with us and answer questions on social and environmental sustainability, including their efforts to protect against modern slavery, their own vendor due diligence processes and to provide supporting evidence for their answers.

We also have access to a data driven tool which provides an indicated risk rating (from low to high) across elements of modern slavery for sub-categories of procurement and suppliers. In particular it looks at child labour, forced labour, human trafficking and forced marriage. This is used to better understand the level of due diligence that should be applied to a supplier. Our plan is to expand our current due diligence programme to a risk-based approach based on the findings of this environmental, social and governance (ESG) risk tool. Those suppliers that do not meet our standards will face an escalation process and will be given the opportunity to make improvements before we make a final determination on whether we engage them as a supplier or not.

Once the supplier has been approved via the firm’s procurement process, ongoing compliance with its obligations is monitored by the relevant business stakeholders.

Our Supplier Code of Conduct
Once suitable suppliers have been identified by our procurement team, they are then required to adhere to our Supplier Code of Conduct (or equivalent standards) as part of the procurement contract between the supplier and the firm. The Supplier Code of Conduct (“Supplier Code of Conduct”) sets out clear standards of business conduct and ethics that our suppliers have to abide by.

Specific examples of what it includes are:

Freedom from forced labour, bonded labour and human trafficking: All employment should be freely chosen by the worker. This means workers should be free to leave their employment at any time (subject to reasonable and paid notice periods) and shall not be subject to any coercion or restriction through, for example, the holding of original copies of employee passports, identity documents or monetary deposits. Further, there shall not be any use of bonded labour. Work should be undertaken for fair compensation and should not be undertaken to repay a debt incurred (for example, as a result of deceptive recruiting practices).
Recruitment agencies: Where recruitment agencies or brokers are used by the supplier, appropriate due diligence and ongoing management should be undertaken to ensure that risks of worker exploitation (such as debt bondage) are effectively mitigated. Reasonable evidence of these activities should be made available to us upon request, within a reasonable notice period.
Child labour: Suppliers should adhere to local laws relating to the minimum working age and not engage in the employment of child labour, directly or indirectly. Suppliers should also ensure that working hours for those of school age are not exceeding the maximum hours on a school day.
Demonstration of reasonable modern slavery due diligence: We expect that our suppliers will maintain an active view on the inherent risks of modern slavery in their supply chain (including third-party certifications in relation to human rights and social compliance standards). Among other modes of inquiry, we expect this to include engaging human rights specialists to perform validation audits of high-risk suppliers on an intermittent, but no less than annual, basis.

Our supplier terms
The obligations set out in the Supplier Code of Conduct are strengthened by our standard supplier terms which provide the firm with the right to terminate agreements by written notice to a supplier with immediate effect if the supplier commits a material breach which is irremediable or, if such breach is remediable, fails to remedy that breach within a period of 30 days after being notified to do so. Being in breach of any applicable law (including the Act) would, in our view, amount to a material breach. However, we would normally first try to work with suppliers who are in breach of their obligations so that any modern slavery issues are eradicated as soon as possible.

Our business
Given the type of work that we do, the recruitment checks that we undertake on our people (which includes an interview process and comprehensive background checks) and the training and policies we have in place to inform and develop staff behaviours, we believe that the risk of human rights infringements (including under the Act) arising within the firm is low. Nonetheless, we remain committed to ensuring that no modern slavery occurs by having appropriate due diligence processes in place and training our people.

Our people
Before joining, we perform extensive pre-screening on our employees, partners and contractors, which include identity checks, reference checks, right to work checks, criminal record checks, and where applicable education and professional qualification checks. This supplements a number of interviews, where recruitment have been trained to observe behaviours. We are confident that these processes flush out any modern slavery issues at the recruitment stage.

We also adhere to paying the Real Living Wage (or equivalent international wage standard) to our employees and contractors across all our locations in the UK and overseas.

Our policies and training
Interval's Code of Conduct (the “Code of Conduct”) represents our commitment to building a better working world. It provides a clear set of standards for our business conduct and ethics that underpin this purpose. The Code of Conduct binds all our people worldwide, regardless of their individual role, position or practice area. It includes a responsibility to report any behaviour that compromises the principles in the Code of Conduct, which includes any form of human rights abuse, including modern slavery and human trafficking. To ensure the Code of Conduct is embedded in the firm’s culture, our staff must complete an annual declaration confirming they have read, understood and are in full compliance with the Code of Conduct. This includes acknowledging that it is their responsibility to speak up when they see any behaviour that they believe is inconsistent with the principles set out in the Code of Conduct. The Code of Conduct is publicly available here: LINK

The firm published a Modern Slavery Statement (the "MSS") shortly after its incorporation. The MSS reinforces the responsibilities and standards expected within and outside of the firm, whilst also reminding our people that we encourage openness and are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery is or may be taking place. In addition to modern slavery, the firm actively takes steps to prevent wider issues regarding harm and abuse of those who work with us, engage with our activities or operate on our premises.

Every new joiner to the firm is required to complete an induction, as part of which details of the Code of Conduct and risk management policies (including the MSS) are provided. Where a specific need is identified (such as for those working in our procurement team), bespoke training is also delivered to enhance the understanding of, and compliance with, the Act and Code of Conduct.

Any breach of the Code of Conduct and/or MSS will be taken very seriously. This can result in disciplinary action, up to and including dismissal without notice. For employees or partners who are members of professional regulatory bodies, any breach will often result in a report of wrongdoing being made to their regulator.

Reporting concerns
Our people are encouraged to raise any questions or concerns that they may have about modern slavery in our business or supply chain via the firm’s central mailbox (anonymously, if they wish) or with a manager or partner.

No complaints or concerns have ever been raised about modern slavery or human trafficking taking place in our business.

If you have any questions regarding our modern slavery statement, please contact us.