Effective Date: Jul 11, 2025| Revised: May 13, 2026
Alkebulan Homes & Villas Ltd is committed to conducting business with integrity, fairness, and respect for human rights. We recognize that modern slavery, forced labour, child labour, and human trafficking are serious violations of fundamental human rights.
Alkebulan Homes & Villas Ltd has zero tolerance for modern slavery, forced labour, child labour, human trafficking, sex trafficking, commercial sexual exploitation of adults or children, and any use of our properties, staff, systems, suppliers, or booking channels to facilitate coercion, abuse, or exploitation.
Scope
This policy applies to:
- All employees, contractors, interns, and consultants of Alkebulan Homes & Villas Ltd. This policy also applies to guest screening, reservation handling, check-in procedures, in-stay monitoring, access control, cleaning and housekeeping teams, security personnel, concierges, building managers, booking platforms, referral partners, and any person acting on our behalf at or in relation to our properties.
- Our suppliers, vendors, and business partners across Kenya and internationally.
Definitions
For the purposes of this policy:
- Modern Slavery: Encompasses slavery, servitude, forced or compulsory labor, bonded labor, child labor and human trafficking.
- Human Trafficking: Recruitment, transportation, transfer, harboring, or receipt of persons by means of coercion, abduction, fraud, or abuse of power for exploitation.
- Sex Trafficking: Recruitment, harbouring, transportation, provision, obtaining, or control of a person for a commercial sex act or other sexual exploitation through force, fraud, coercion, abuse of power, or where the person is a child. In the case of a child, any exploitation for a commercial sex act or sexual exploitation constitutes sex trafficking. A child cannot consent to commercial sex exploitation. Proof of force, fraud, coercion and abuse of power are therefore not required in the case of children.
Our Practices and Standards
Alkebulan Homes & Villas Ltd. gives effect to this policy through the following employment, recruitment, supplier, guest-verification, safeguarding, and property-use standards and controls.
Employment Standards
- Prohibit the use of forced, bonded, or involuntary labor.
- Ensure employees are free to leave employment after reasonable notice.
- Prohibit child labor in accordance with Kenyan law and international standards.
- Provide fair wages, benefits, and working conditions.
Recruitment Practices
- Prohibit recruitment fees and passport retention.
- Ensure workers are hired through ethical recruitment processes.
Suppliers and Contractors
All relevant suppliers and service providers must comply with this policy, cooperate with safeguarding procedures, complete any required training, protect personal data appropriately, and report indicators of exploitation, suspicious occupancy, or unauthorised access without delay.
- Require all suppliers and service providers (including cleaning, security, maintenance, and hospitality services) to comply with this policy.
- Conduct risk-based due diligence on suppliers to ensure compliance.
Guest Verification Controls
As part of our commitment to preventing human trafficking and exploitation within the hospitality sector, Alkebulan Homes & Villas Ltd. requires that all guests complete mandatory identity verification through Truvi before confirming a reservation. This measure ensures that bookings are traceable to verified individuals, helps prevent the use of our properties for unlawful purposes, and strengthens our overall safeguarding framework. We regard ID verification not only as a security measure but also as an essential control to uphold our responsibility to protect vulnerable individuals and to maintain ethical business practices.
Risk Indicators and Property-Use Controls
Alkebulan Homes & Villas Ltd monitors for reasonable indicators of exploitation or criminal misuse, including refusal to verify identity, last-minute or evasive bookings, mismatched guest details, unexplained changes in occupancy, attempts to bypass approved payment or communication channels, excessive foot traffic, repeated linen or supply requests inconsistent with declared occupancy, visible coercion, or any behaviour suggesting a person may be under control or at risk. Staff must document and escalate such indicators in line with this policy.
Transparency and Training
- Train employees and managers to identify and report potential risks of modern slavery.
- Maintain transparent reporting channels for concerns.
- Relevant staff and contractors will receive periodic training on modern slavery and sex-trafficking indicators, including booking-stage warning signs, check-in concerns, in-stay behaviours, child safeguarding, record-keeping, escalation routes, and personal-data handling.
Responsibilities
- Board of Directors & Senior Management: Overall accountability for implementing and monitoring this policy.
- Managers: Ensuring compliance within their departments and supplier relationships.
- Employees: Reporting concerns related to modern slavery or unethical practices.
Reporting Concerns
- Concerns may be raised through our designated safeguarding reporting channel email safeguarding@alkebulanafrica.one.
- Matters involving immediate danger, suspected child exploitation, violence, coercion, unlawful detention, or active trafficking risk must be escalated immediately to management and, where appropriate, to law-enforcement or child-protection authorities. Alkebulan Homes & Villas Ltd will protect reporters from retaliation and maintain a confidential internal case log.
- Concerns will be investigated promptly, with assurance of non-retaliation for whistleblowers.
Escalation Procedure
Where a staff member, contractor, property manager, or service provider identifies a concern regarding suspected danger, exploitation, violence, coercion, unlawful detention or active trafficking risk, they must:
- Record the date, time, property, booking reference, people involved, and observed indicators.
- Avoid confronting suspected victims, traffickers, or guests in a way that may increase risk.
- Escalate the concern immediately to management and the designated safeguarding contact.
- Where appropriate, contact law-enforcement, emergency services or child protection authorities.
- Preserve relevant records, including booking information, communications, access logs, identity-verification records, housekeeping and security staff observations and incident notes.
- Maintain confidentiality and share information only with those who require such information for safeguarding, legal or investigative purposes.
Data Protection and Privacy
Alkebulan Homes & Villas Ltd is aligned to GDPR standards for data protection and Privacy. Where applicable, this includes compliance with the Kenya Data Protection Act and any other applicable privacy laws, including GDPR where relevant. When processing guest identity and safeguarding information, Alkebulan Homes & Villas Ltd will collect only data reasonably necessary for safety, fraud prevention, legal compliance, and the prevention or investigation of modern slavery, sex trafficking, and related abuse. Access will be restricted to authorised personnel, records will be retained only for a defined period, verification vendors and other processors will be subject to appropriate contractual controls, and personal data will be disclosed only where permitted or required by law, or where necessary to protect individuals from serious harm.
Enforcement and Consequences
We will review this policy and related operating procedures at least annually and after any serious incident, legal development, or material safeguarding concern. Review factors may include verification completion rates, refused bookings, occupancy breaches, incident trends, supplier compliance, training completion, and lessons learned from investigations.
Suppliers or contractors found in breach of this policy may have contracts terminated.
Continuous Improvement
We will review this policy and related operating procedures at least annually and after any serious incident, legal development, or material safeguarding concern. Review factors may include verification completion rates, refused bookings, occupancy breaches, incident trends, supplier compliance, training completion, and lessons learned from investigations.
Approval
This policy is approved by the Board of Directors of Alkebulan Homes & Villas Ltd.
