Our policies

For cities

At CitySuites we take privacy very seriously and we are committed to protecting it.

This policy explains when and why we and the companies of our Group (what here means our subsidiaries, our ultimate holding company and its subsidiaries from time to time, as defined in section 1159 of the UK Companies Act of 2006, and may also include other companies that are associated through our management control, but may not be a group company) collect personal information about people who are clients, future clients, previous clients and others who may be connected with they, how this information is used, the conditions in which it is found can be disclosed to others and how it is kept safe.

This policy may change from time to time, so we recommend that you visit this page from time to time to make sure you are aware of all changes and that you are satisfied.

This policy was last updated on Jan 02, 2022.

About us

City Suites Management Limited (registered company number 10193362), referred to in this document as "CitySuites" is the data controller in relation to the processing activities described below. This means that CitySuites decides why and how your personal information is processed.

This policy also covers other Group companies that are listed in Annex 1 of this policy. When dealing with one of these other Group companies, CitySuites will be the "controller" of your personal information.

A "data controller" is an organisation that decides why and how your personal information is processed.

When this policy refers to "we," "our" or "us" below, unless otherwise mentioned, it refers to the particular company that is the controller of your personal information.

How we collect your personal information

This is information about you that you provide us, for example:

• Visiting our website (citysuites.com);
• Using our web or mobile applications (including online chat);
• Viewing or following our channels on any social networking platform;
• Corresponding to us by phone, email or otherwise;
• Attend one of our organised or sponsored events;
• Make a reservation in person, by phone or through one of our designated agents

and it is provided by you voluntarily. This includes the information provided when registering to use our site, expressing your interest in making a reservation, making a reservation, subscribing to the services we provide through our websites and other channels, requesting additional information, material or associated services , manage your personal data (including access to documentation and participation in correspondence with us by phone, email or otherwise). If you complete any survey that we request for research purposes, we will also collect information in such circumstances. The information you provide will usually include your name, address, email address and phone number (s), age and date of birth, details of your specific inquiry, details of your employer and / or job function, and may include records of any correspondence and responses to marketing campaigns.

Personal information we collect about you:

We may collect the following information, either by request or automatically: your contact information, geographic and demographic information, preferences and interests and other information you provide through, among other things, the answers provided in surveys and visits to our site web and application, including information on the information and resources accessed. We can also automatically collect technical information, including anonymous data collected by the hosting server, the Internet Protocol (IP) address used to connect your computer or device to the Internet, the browser type and version, the time zone settings , the types of browser add-ons and Versions, operating system and platform. Please, check our Cookies Policy for more information. We may also collect any personal information that you allow to be shared that is part of your public profile (s) in third-party social networks, including, among others, the time zone settings, the types and versions of add-ons of the browser, the operating system and the platform. , and their preferences, interests and other behaviours.

Personal information we can receive from other sources:

We may also obtain certain personal information about you from sources outside of our business, which may include both our Group companies (where you provided the details above) and other third-party companies where you previously provided your consent for the exchange. of personal information. In accordance with the privacy policies of said third parties. The personal information we receive from third party sources is usually your contact information, certain demographic information, and may also include information about the information you have previously requested and / or the preferences you have previously expressed about specific areas of interest.

Types of personal information we process on you

We can process a variety of personal information about you. To facilitate understanding of the information we use about you, we divide this information into categories in the list below and provide a brief explanation of the type of information generally covered by each category.

Behaviour like your activities, actions and behaviours.

Biographical As your workplace and job title, which can be used to address, send or communicate a message.

Geographical location information that contains or reveals the location of your electronic devices

Identification information contained in a formal identification document such as your passport

Bank / billing information used to collect from you or return the money owed.

Credit your application for credit terms and information related to the provision of credit for you.

Fraud Information regarding the occurrence, investigation or prevention of fraud.

Legal information related to legal claims made by you or against you or the claims process

Reservation transactions The information related to the accommodation reservations and the auxiliary services that are provided to you and

Correspondence information contained in our correspondence or other communications with you about our products, services or businesses

How we use your personal information

The purposes for which we use your information and the legal basis under the data protection laws on which we rely to do this are explained below.

Where there is a legal requirement

We will use your personal information to comply with our legal obligations, such as: (i) to assist any public authority, industry regulator or criminal investigation agency; (ii) to correctly identify you when you contact us and / or to verify the accuracy of the information we have about you.

Where it is required to complete or comply with a Contract

We may use and process your personal information when we sell you a product or products, provide (or continue to provide) any service, where we organise the supply of products or services from third parties as your designated agent. , or where you are in detailed conversations with us about the sale or purchase of a product or service. We will use this information to ensure that the terms of the relevant contracts are met or complied with. This may include circumstances in which we ourselves are not part of the contract, however, we have been designated to administer or provide services related to that contract. For the purposes of this description, a "contract" generally means an occupancy agreement, lease or administration service. See "Type of personal information we process" about you above for details about the types of personal information we process for these purposes.

Where we have evaluated there is a legitimate interest

We may use and process your personal information when we deem it necessary for our legitimate business interests, your legitimate interests as a guest or potential guest, or the legitimate interests of a Group company, for the following purposes:

• to correspond or communicate with you in general, for example, with the company or other relevant news;
• for marketing activities (other than where we rely on your consent to contact you by email or text message with information about our products and services or share your details with third parties to do the same, as explained below);
• for analysis to inform our future marketing strategy and / or to improve or personalise your customer experience (such as improving the quality or relevance of the information we provide in the future);
• to verify the accuracy of the data we have about you and create a better understanding of you as a client or potential client;
• for the security of the network and information, so that we can take measures to protect your information against loss or damage, theft or unauthorised access;
• for the prevention of fraud and other criminal activities;
• to comply with a request from you regarding the exercise of your rights (for example, when you requested that we not contact you for marketing purposes, we will keep a record of this on our deletion lists in order to comply with your request);
• to review facts, evaluate and improve our service to clients through recordings of any call in our offices;
• for the management of any query, complaint or claim presented;
• for the establishment and defence of our legal rights.

Where you have provided the consent

We may use and process your personal information on the basis of your consent for us to do so, for the following purposes:

• To contact you by email or SMS with marketing information about our products and services, predominantly accommodation and accommodation services.
• To share your information with certain Group companies to communicate with you with marketing information about similar products and services.
• We will never share or sell your data with unconnected third parties to obtain business benefits without your knowledge and consent.

You may withdraw your consent for us to use your information in any of these ways at any time. See Withdraw your consent for more details.

Others who can receive or have access to your personal information

Group companies

We may share your information with other Group companies. You may use your personal information in the ways that are detailed in the How we use your personal information above section, in relation to specific products and / or complementary or complementary services, for example, products and services that only they can provide for regulatory reasons. , or products and services that are similar to those we offer but that may be under the name of a different brand. Some of the companies in our Group can also be service providers for us, as explained in the next section.

See the beginning of this policy for a description of what we mean by the Group companies with which we can share your personal information in this way.

Our suppliers and service providers

We may disclose your information to certain service providers, agents, subcontractors and other selected organisations when necessary for the purpose of providing services to us or directly to you on our behalf. Such third parties may include cloud service providers (such as hosting and software service providers), online booking agents or aggregators, digital and marketing agencies, and administrative service providers.

When we use third party service providers in this way, we only disclose any personal information that is necessary for them to provide their services and we have a current contract that requires them to keep your information secure and not use it. in accordance with our specific instructions for the purposes foreseen and established in this Policy.

Payment processors for credit/debit cards

When you purchase certain products or services through our websites, by phone or at one of our residences or locations, a third-party payment processing agent who specialises in secure online capture can process a payment by credit card or debit with your instruction. Processing of credit / debit card transactions. If you have any questions regarding safe transactions, ask us at the time of making the payment or contact us using the details at the end of this policy.

We do not store or keep a record of your credit card details on our own websites or within our own systems.

Other ways we can share your personal information

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to a third party or as part of any restructuring or business reorganisation. We may also transfer your personal information if we have an obligation to disclose or share it to comply with any legal obligation, for example, to detect or report a crime, to enforce or enforce the terms of our contracts or to protect the Rights, property or security of other data subjects. If/when we do, we will always take steps to ensure that your privacy rights remain protected and your rights are respected.

Where we keep your personal information

The information you provide may be transferred to countries outside the EEA, for example, where any of the companies in our Group that need access to that information is incorporated in a country outside the EEA, or if any of our servers or ours Third Service providers are occasionally located in a country outside the EEA. These countries may not have data protection laws similar to those in the United Kingdom.

If we transfer your information outside the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as described in this policy. This is because some countries outside the EEA do not have the same adequate data protection laws equivalent to those in the EEA. These steps may include, for example, imposing contractual obligations on the recipient of your personal information or ensuring that recipients subscribe to other relevant regulatory regimes or best practices that aim to ensure adequate protection. Contact us using the details at the end of this policy to obtain more information about the protections we implement in these circumstances.

If you use our services, access our systems or view any of our content while you are outside the EEA, your information may be transferred outside the EEA to provide those services.

How long do we keep your personal information?

When we collect your personal information, the amount of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not keep personal information in an identifiable format for longer than we consider necessary.

The time during which we store your personal data may also vary according to the legal basis we use.

When you contact our offices by phone, these calls can be recorded. These call recordings are retained for no more than 90 days.

Where your personal information is required to complete or comply with a Contract

We may need your personal information to comply with our own legal and accounting responsibilities, and / or to establish, present or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date we no longer need it for any of the purposes listed in How we use your personal information mentioned above. When we are only required to retain part of your information for these purposes, we will make every reasonable effort to "minimise" that data and not to retain any information that we do not have to keep for 7 years.

The only exceptions to this are where:

• The law requires us to keep your personal information for a longer period of time or to remove it beforehand;
• Exercise your right to have the information erased (when applicable) and we do not need to keep it in relation to any of the reasons allowed or required by law (see more information How to delete your personal information or restrict its processing below); or
• In limited cases, the law allows us to keep your personal information for longer, as long as we implement certain protections

Where we have evaluated there is a legitimate interest

If you are a citizen of an EEA country, we will not retain your personal data for more than 2 years after a Legitimate Interest Assessment has been performed or renewed, unless:

We identify the circumstances that, in our reasonable and professional judgment, indicate that there is a legitimate interest in progress; or

When the legitimate interest on which we have based has expired, first (or later) we have obtained your consent (see below)

If you are not a citizen of any EEA country, we can keep your personal data for more than 2 years when we consider it valuable and justifiable, subject at all times to defend your rights as a subject of the data.

Where you have provided the consent

We will retain your personal data as long as we consider it valuable and justifiable, subject at all times to defend your rights as subject of the data (including the right to have your consent withdrawn and the right to have your personal data deleted).

Even when you have given your consent and you have not withdrawn it, at any time we can make the decision not to keep your personal data when we consider that it is no longer worthwhile or justified.

Security of data and links to or from other organisations

We are committed to ensuring that your information is kept secure in systems that can be controlled and protected in accordance with best data security practices. To prevent unauthorised access or disclosure, we implement appropriate physical, electronic, and administrative procedures to safeguard and protect the information we collect from you. Wherever possible, we only store information in structured systems (databases) that can only be accessed with secure passwords.

Occasionally, it may be necessary to store or transfer some of your personal information in an unstructured form, such as paper or document formats that are necessary to allow us to collect and process that information in accordance with the purpose. In these cases, we will make every reasonable effort to ensure that procedures and controls are in place to maintain security and access to that information.

Unfortunately, the transmission of information through the internet is never completely secure. Although we will do our best to protect your personal information, we can not guarantee the security of your information transmitted to or from our website at all times and, therefore, any transmission is at your own risk. Once we have received your personal information, we implement reasonable and adequate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration or unauthorised access.

Our websites may contain links to other websites managed by other organisations. In the same way, we may send it from time to time to other organisations that are not Group companies and to which you can also provide personal information. This policy does not apply to those other organisations where this happens, therefore, we recommend that you read their privacy statements separately. We can not be responsible for the privacy policies and practices of other websites or third parties, even if you access those websites or contact those organisations through links or contact information that we provide.

In addition, if you have linked to our website, a contact data form or any other material that we have published electronically from a third party website or an email sent by a third party, we are not responsible for the privacy policies and practices of The owners and operators of these third parties recommend that you also review their privacy statements.

When we collect and process any particularly sensitive personal information, for example, your banking information, we will apply additional security controls to protect that data.

When we have given you (or have chosen) a password that allows you to access certain information that we have in any of our systems, you are responsible for maintaining the confidentiality of this password. We ask you not to share your password with anyone and to inform us as soon as possible if you believe your password has been stolen, exposed or compromised in any way.

Your rights

If you are a citizen of an EEA country, you have several rights in relation to your personal information under the data protection law, which are summarised below. Not all of these rights may be applicable to citizens of countries outside the EEA. In connection with certain rights, we may request information to confirm your identity and, when appropriate, to help us locate your personal information. Except in exceptional cases, we will respond within one month from (i) the date we confirm your identity or (ii) when it is not necessary to do so because we already have this information, from the date we received your request.

Accessing your personal information.

• You have the right to make a reasonable request to obtain a copy of the information we have about you by sending us an email or by writing to the address at the end of this policy. We may not provide you with a copy of your personal information if it concerns other people or if we have another legal reason to retain that information. In limited circumstances, you may have a right to data portability (that is, to ask us to create a file to transfer you or a different service provider) from the personal data electronically processed about you.
• Correcting and updating your personal information.
• The accuracy of your information is important to us and we are always willing to make sure that we can review and correct regularly and easily the information we have about you. If you change any personal information, in particular your name, address, email address and contact telephone numbers, or if you discover that any of the other information we have is inaccurate or outdated, please let us know as soon as possible. using any of the details described at the end of this policy.

Withdrawing your consent

• When we rely solely on your consent as the legal basis for processing your personal information, as set forth in How we use your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you wish to withdraw your consent to receive any direct marketing to which you have previously accepted, you may do so through our unsubscribe links included in such marketing that we send you electronically. If you withdraw your consent, our use of your personal information before you leave is still legal.
• Objecting to our use of your personal information and the automated decisions made about you. When we depend on a legitimate interest identified as the legal basis for processing your personal information for any purpose, as explained in How We Use Your Personal Information, you may object to the use of your personal information for these purposes by email or in writing. To us in the address at the end of this policy. Except for the purposes for which we are certain that we may continue to process your personal information, we will stop processing your personal information temporarily in line with your objection until we have investigated the matter. If we accept that your objection is justified in accordance with your rights under the data protection laws, we will stop using your information permanently for those purposes.
• Otherwise, we will provide you with our justification about why we need to continue using your data.
• You may object that we use your personal information for direct marketing purposes and we will automatically comply with your request. If you wish to do so, use our unsubscribe links in any type of marketing that we send electronically.
• Delete your personal information or restrict its processing
• In certain circumstances, you may request that your personal information be removed from our systems by sending us an email or by writing to the address at the end of this policy. Unless there is a reason why the law allows us to use your personal information for a longer period of time, we will make every reasonable effort to comply with your request.
• You may also ask us to limit the processing of your personal information when you believe it is illegal for us to do so, that you have opposed its use and that our investigation is pending or requires us to keep it in relation to legal proceedings. In these situations, we can only process your personal information while your processing is restricted if we have your consent or are legally authorised to do so, for example, for storage purposes, to protect the rights of another person or company or in connection with legal proceedings.

Complaining to the UK data protection regulator

• You have the right to file a complaint with the Office of Information Commissioners (ICO) if you are concerned about the way we have processed your personal information. Visit the ICO website www.ico.org.uk for more information.

Changes to this policy

We may revise this policy from time to time and any changes will be notified to you by posting an updated version on our website (s). In some circumstances, we may also notify you or contact you, for example, by email, to inform you of the changes. Any change of this type will become effective 7 days after the date on which we publish the modified terms on our website. We recommend that you regularly check the changes and review this policy each time you visit our websites. If you do not agree with some aspect of the updated policy, you must notify us immediately to ensure that we comply with our obligations to ensure that you can exercise your rights.

Contact us to get more information

Address any questions about this policy or about the way we process your personal information to our team responsible for legal issues and compliance using the contact details below.
If you wish to write to us, write to City Suites Management (legal and compliance team), The Box, Horseshoe Lane, Alderley Edge, Cheshire SK9 7QP, United Kingdom
The email address for data protection inquiries is giles.beswick@citysuites.com
If you prefer to talk to us by phone, call 0161 322 2225 or +44 (0) 161322 2225 from abroad.

Schedule 1

Group Companies

Select Property Group (Holdings) Limited, registered company number 8958577

Select Property Group Limited, registered company number 5071388

Select Property Group Leisure Holdings Limited, registered company number 10133864

Cookie Policy

Effective Date: 07-Jul-2023
Last Updated: 07-Jul-2023

What are cookies?

This Cookie Policy explains what cookies are and how we use them, the types of cookies we use i.e, the information we collect using cookies and how that information is used, and how to manage the cookie settings.

Cookies are small text files that are used to store small pieces of information. They are stored on your device when the website is loaded on your browser. These cookies help us make the website function properly, make it more secure, provide better user experience, and understand how the website performs and to analyze what works and where it needs improvement.

How do we use cookies?

As most of the online services, our website uses first-party and third-party cookies for several purposes. First-party cookies are mostly necessary for the website to function the right way, and they do not collect any of your personally identifiable data.

The third-party cookies used on our website are mainly for understanding how the website performs, how you interact with our website, keeping our services secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience and help speed up your future interactions with our website.

Types of Cookies we use

• Necessary
• Functional
• Analytics
• Performance
• Advertisement
• Uncategorised

Manage cookie preferences

You can change your cookie preferences any time by clicking here.

This will let you revisit the cookie consent banner and change your preferences or withdraw your consent right away.

In addition to this, different browsers provide different methods to block and delete cookies used by websites. You can change the settings of your browser to block/delete the cookies. Listed below are the links to the support documents on how to manage and delete cookies from the major web browsers.

Chrome: https://support.google.com/accounts/answer/32050

Safari: https://support.apple.com/en-in/guide/safari/sfri11471/ma

Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox?redirectslug=delete-cookies-remove-info-websites-stored&redirectlocale=en-US

Internet Explorer: https://support.microsoft.com/en-us/topic/how-to-delete-cookie-files-in-internet-explorer-bca9446f-d873-78de-77ba-d42645fa52fc

If you are using any other web browser, please visit your browser’s official support documents.

Cookie Policy Generated By CookieYes - Cookie Policy Generator.

Introduction - Supplier Code of Conduct

This Supplier Code of Conduct (our ‘Supplier Code’) sets out the standards our suppliers are expected to adopt in relation to managing working conditions, business ethics and their environmental impacts. It is CitySuites & Embankment Kitchen – Embankment Café policy to conduct every aspect of our business with honesty, integrity and openness, respecting human rights and the interests of our employees, guests, customers and third parties. Our suppliers are essential partners in delivering the commitments and standards we have set. To support this effort, we expect all our suppliers to hold themselves to high standards of social and environmental responsibility. This Supplier Code applies to all suppliers and partners who supply products or services related to contracts or purchase orders with CitySuites & Embankment Kitchen – Embankment Café and its subsidiaries. Where we refer to “suppliers” in this Supplier Code, this includes suppliers, subcontractors, service providers, professional service providers, consultants, intermediaries, and agents. We expect you to cascade these principles throughout your own supply chain.

Business Ethics

CitySuites & Embankment Kitchen – Embankment Café is committed to conducting its business in accordance with the highest ethical standards and in compliance with all applicable laws, rules and regulations. Suppliers are expected to share their principles, uphold their standards and for each to develop policies and programs as appropriate to ensure that all workers understand and adhere to these standards.

Conflict of Interest

Conflicts of interest run against the fair treatment CitySuites & Embankment Kitchen – Embankment Café, expects. Suppliers must disclose any personal relationships held between their employees and CitySuites & Embankment Kitchen – Embankment Café employees to avoid personal business activities and financial interests which could be against their responsibilities to CitySuites & Embankment Kitchen – Embankment Café.

Bribery and Anti-corruption

Suppliers must not, directly or through others, offer, promise, give or accept any form of payment or incentive to gain an improper business advantage or for the purpose of influencing the actions of the recipient. Accounting records and supporting documents must describe and reflect the nature of the underlying transactions. Suppliers must not engage in fraud, bribery (including facilitation payments), kickbacks, money laundering, embezzlement, extortion, or any other form of corruption. Suppliers must be committed to complying with applicable anti-corruption laws, such as the UK Bribery Act 2010.

In addition, all suppliers that either have a presence in the UK or who perform transactions within the UK must ensure that they do not undertake any actions that could be seen as facilitating tax evasion in any form. Suppliers must be committed to complying with the UK tax authorities' legislation entitled ’Corporate criminal offence of failure to prevent the facilitation of tax evasion. Suppliers must ensure that they have appropriate processes and procedures in place such that HMRC would be satisfied that no liability sits with the supplier.

Gifts Travel and Entertainment

Suppliers must not provide lavish or otherwise inappropriate gifts, fees, favours, or other compensation, including travel and entertainment, that are intended to influence or may appear to influence, a business decision. The offering of gifts, travel and entertainment may create an inappropriate obligation or expectation or appearance of an improper exchange. It can also raise issues even if no benefit was ultimately provided.

Fair Competition

Competition and anti-trust laws prohibit a variety of business practices that restrict free and fair competition. Violations of such laws are very serious and can result in significant fines and other penalties. Individuals could even face prison. Suppliers must be committed to conducting business in accordance with principles of fair competition, which includes treating competitors in a businesslike and fair manner and avoiding utilizing competitors’ procedures, potential problems, or rumours in promoting our own business. Suppliers must not engage in illegal cooperation with competitors including bid rigging, price fixing, market allocations or any other prohibited conduct that limits fair competition. Suppliers will not share with CitySuites & Embankment Kitchen – Embankment Café information they receive from or about CitySuites & Embankment Kitchen – Embankment Café competitors or bids they are making to CitySuites & Embankment Kitchen – Embankment Café competitors. Suppliers must always report anti-competitive behaviour if they see or suspect it.

Confidential Information

Information is considered confidential to CitySuites & Embankment Kitchen – Embankment Café if it has value to CitySuites & Embankment Kitchen – Embankment Café and is not publicly available. CitySuites & Embankment Kitchen – Embankment Café employees and suppliers have a responsibility to keep confidential information safe. Suppliers must secure CitySuites & Embankment Kitchen – Embankment Café private and confidential information in their possession, use it per the instructions of CitySuites & Embankment Kitchen – Embankment Café and safeguard it from unapproved or unintended disclosure. This obligation continues after the business relationship with CitySuites & Embankment Kitchen – Embankment Café ends.

We are committed to protecting confidential information related to external parties, our business activities, or employees. We shall take measures to safeguard our documents and devices that contain confidential information, as well as trade secrets and all other confidential information of our business partners known to us through our business relationships.

Personal Information

CitySuites & Embankment Kitchen – Embankment Café recognises its duty to respect personal information and ensure it is protected and handled responsibly and only used for the purposes for which it is provided. Suppliers must ensure that all personal information is controlled in accordance with, and their data and information systems comply with, applicable laws and regulations. CitySuites & Embankment Kitchen – Embankment Café expects its suppliers to manage personal information in accordance with the following data protection principles:

• Process personal information fairly and lawfully
• Obtain personal information only for specified, explicit and legitimate purposes
• Ensure personal information is adequate, relevant, and not excessive
• Ensure personal information is accurate and, where necessary, kept up to date
• Not keep personal information for longer than is necessary
• Process personal information in accordance with the rights of the individual
• Keep personal information secure
• Not transfer personal information unless there is adequate protection in place

Personnel/ Labour standards/ Terms of employment

CitySuites & Embankment Kitchen – Embankment Café has a diverse workforce and supply base; with different skills and capabilities coming from many cultures. The diversity has helped make CitySuites & Embankment Kitchen – Embankment Café the success it is today and is vital to our future. Suppliers must ensure employment is based on ability and not on beliefs or any other personal characteristics.

Salaries and working hours

Suppliers must ensure that the conditions of employment offered to employees, including salaries and benefits, meet the minimum requirements in national law and/or collective agreements. Suppliers shall also ensure that each employee is entitled to a written labour contract, and must provide reasonable working hours.

Equality, Inclusion, and Diversity

CitySuites & Embankment Kitchen – Embankment Café wants to be a place of mutual trust and respect, which embraces diversity and values everyone for their merits. We expect our suppliers to do the same. Suppliers should be committed to embracing and promoting equality and diversity, as well as mutual trust and respect in our work environment.

Discrimination and Harassment

Suppliers must treat all employees with respect and dignity, ensuring that no inappropriate treatment of others, such as discrimination, intimidation, or harassment, takes place in the workplace. This includes discrimination based on sex, race, colour, national or ethnic origin, sexual orientation, gender identity or expression, religion, political beliefs, trade union activity, marital status, caring responsibilities, disability age or citizenship.

Freedom of movement or personal freedom

Suppliers must not unreasonably restrict workers’ freedom of movement. Workers shall not be physically confined to the workplace or related premises, nor shall any other coercive means be used to restrict workers’ freedom of movement or personal freedom.

Freedom of Association

CitySuites & Embankment Kitchen – Embankment Café recognises the importance of open communication and direct engagement between workers and management and expects its suppliers to do the same. Suppliers are to respect the rights of workers to associate freely and communicate openly with management regarding working conditions without fear of harassment, intimidation, penalty, interference, or reprisal.

Slavery, Forced Labour and Human Trafficking

CitySuites & Embankment Kitchen – Embankment Café does not tolerate slavery, forced labour, or human trafficking in any form and CitySuites & Embankment Kitchen – Embankment Café will not knowingly work with suppliers who engage in these practices or permit their subcontractors to engage in these practices. Suppliers are expected to fully comply with the requirements of applicable slavery, including without limitation the UK Modern Slavery Act 2015.

Health and Safety

Safe and Healthy Work Environment

Suppliers must provide a safe and healthy working environment that minimizes health and safety risks and supports accident prevention and ensures the health and safety of all personnel and all others affected by their activities. Suppliers are required to, and shall require their subcontractors to, comply with all applicable health and safety laws and regulations in the jurisdictions in which they operate, and to provide workers with access to appropriate personal protective equipment at no cost.

Sanitation, Water, and Housing

Supplier workers must be provided with ready access to clean toilet facilities and potable water. If the supplier provides worker accommodation, it is to be maintained in a clean and safe manner, and provide appropriate emergency egress, fire safety measures, hot water for bathing and showering, adequate heat and ventilation, and reasonable entry and exit privileges.

Human rights

CitySuites & Embankment Kitchen – Embankment Café respects human rights as a fundamental part of our business and values.

Suppliers must recognise their responsibility to promote and respect internationally proclaimed human rights when conducting their business. Suppliers will identify, prevent or mitigate any adverse human rights impacts caused or contributed to by their operations to avoid any infringement on the rights of others and also identify impacts that are directly linked to their operations where they are acting for or in connection with our operations.

Child labour

CitySuites & Embankment Kitchen – Embankment Café does not use child labour and expects suppliers to operate on the same basis and comply with local laws regarding the minimum age of employees.

Forced labour

In line with CitySuites & Embankment Kitchen – Embankment Café, zero-tolerance approach to modern slavery of any kind and its commitment to acting ethically, transparently and with integrity in all our business dealings and relationships, suppliers must not use any type of involuntary or forced labour, including indentured, bonded, slave or human trafficked labour. All work must be voluntary, and workers should have the freedom to terminate their employment in accordance with established laws, regulations and rules.

Environmental Responsibility & Community Engagement

CitySuites & Embankment Kitchen – Embankment Café recognises our impact on society, the economy, and the planet, and aims to make a positive difference.

Environmental

CitySuites & Embankment Kitchen – Embankment Café works to continuously assess and reduce our environmental impact. CitySuites & Embankment Kitchen – Embankment Café aims to prevent environmental damage and minimise our use of energy and resources. Suppliers must comply with all applicable environmental laws, regulations, and operating permits, as well as obtaining required certificates. Suppliers must strive to minimize their negative impacts on the environment by reducing or optimizing their use of resources, including energy and water, and by utilizing systems for recycling and reusing materials.

Water

Suppliers are encouraged to take steps to conserve, reduce the use of, and reuse water in their own operations. Suppliers are also encouraged to manage water resources to ensure their operations do not prevent access to sufficient safe water, sanitation and hygiene for all users in surrounding communities, including those both up and downstream from their facilities.

Waste

Suppliers are encouraged to take concrete steps to minimize or eliminate waste across their operations and those of their suppliers. Any waste, and in particular hazardous waste, must be managed in a responsible manner. Chemicals and other materials posing a hazard if released into the environment should be identified and managed to ensure safe handling, movement, storage, recycling, reuse or disposal. All workers who handle waste and hazardous wastes must be properly trained on how to deal with substances and the potential hazards the material presents if mismanaged or released to the worker and environment. Suppliers must only use permitted transporters and hauliers with a positive record of operating safely and complying with applicable transportation laws and best management practices.

Community Relations and Engagement

CitySuites & Embankment Kitchen – Embankment Café regards being a good corporate citizen as central to how we do business. Supporting the community brings real benefits to our guests/ customers and our colleagues. Suppliers are encouraged to contribute to the communities and countries in which they operate.

Management practices

Record keeping

Suppliers are required to accurately record and disclose information regarding their business activities, structure, financial situation, and performance in accordance with applicable laws and regulations and prevailing industry practices. In addition, suppliers must use sound financial practices and ensure transparency in financial dealings by implementing and maintaining adequate internal controls.

Monitoring of Compliance

Suppliers are expected to review their operations and verify compliance with CitySuites & Embankment Kitchen – Embankment Café Supplier Code of Conduct.

Supply Chain

Suppliers are expected to review their operations and verify compliance with CitySuites & Embankment Kitchen – Embankment Café Supplier Code of Conduct.

Violations of the Code

Suppliers must inform CitySuites & Embankment Kitchen – Embankment Café of any suspected breach of these requirements without delay. In addition, Suppliers are encouraged to reflect the content of these requirements in their agreements with their subcontractors. Failure to comply with the Supplier Code of Conduct may result in the discontinuance of current and/or the prevention of future business relationships.

Sanctions

CitySuites & Embankment Kitchen – Embankment Café and its subsidiaries, as well as its employees, strives to comply with all economic sanctions laws, regulations, embargoes or restrictive measures (”Sanctions”) to which it is subject and not engage in any business that will violate applicable Sanctions.  CitySuites & Embankment Kitchen – Embankment Café will maintain effective measures to seek to ensure compliance with and awareness of its Sanctions related obligations.

CitySuites & Embankment Kitchen – Embankment Café expects its suppliers to conduct their business in an ethical and compliant way at all times, in compliance with all applicable Sanctions. Therefore, Suppliers must:

• be able to evidence that they fully comply with all Sanctions relevant to their business.
• be fully transparent about their ultimate beneficial owners.
• be able to evidence that they maintain effective measures to ensure compliance with and awareness of their Sanctions-related obligations.
• be able to evidence training and support for their employees and contract workers regarding Sanctions and other compliance matters.
• respect and support CitySuites & Embankment Kitchen – Embankment Café vigilant requirement in monitoring external parties that may be on a sanctions list or may have related companies in countries subject to Sanctions; and
• immediately report to CitySuites & Embankment Kitchen – Embankment Café any likely, or actual, contravention of Sanctions.

Questions & Raising Concerns

Suppliers are encouraged to reach out to the CitySuites & Embankment Kitchen – Embankment Café Operational / Procurement team with any questions pertaining to the Supplier Code of Conduct or whenever there are questions related to the appropriateness of any activity connected to their supplier relationship with CitySuites & Embankment Kitchen – Embankment Café. In addition, reports of any ethically questionable behaviour must be made to the Group Procurement team.

CitySuites Ltd. Environmental, Social and Governance (ESG) Policy

1. Purpose

CitySuites is a five-star luxury ApartHotel situated in Central Salford, offering luxury self-contained apartments, leisure facilities and dining. It is our commitment to offer an indulgent experience whilst being able to demonstrate to any interested party, including staff, guests and the general public, that we act ethically and responsibly in all aspects of environmental, social and governance (ESG) throughout our operations. See our environmental commitment page for more information.

This policy outlines our aim to help us deliver long-term value for our stakeholders, communities and the environment by integrating ESG considerations into our day-to-day business activities.

2. Training

We are entirely dedicated to being an environmentally and socially responsible organisation. We want to embed strong environmental principles across all aspects of our operations and continually improve our performance. To support this, we developed an Environmental Management System (EMS) in 2021, which meets the requirements of BS 8555:2016, which is under yearly review.

This includes an external environmental review of our current operations, followed by the creation of formalised procedures and processes to ensure compliance with the following:

• The prevention of pollution through identification and careful control of any aspect of the business which may impact the environment
• Fulfil the organisation’s compliance obligations as they relate to the environmental aspects of the business, which is supported by periodic compliance checks
• Continual environmental improvement through the setting, reviewing, and updating of environmental objectives and targets which relate to our most significant aspects

3. Energy, Water and Waste

We are fully committed to the protection of the environment by reducing our impacts through energy efficiency, resource efficiency, water reduction, waste reduction and recycling. We firmly believe that ESG management is crucial to our long-term growth and profitability.

3.1 Energy

Whether it is heating our indoor pool or cooking guests’ delicious meals, we depend on energy to power our business. Equally, we know that this energy use impacts the planet. So, we are delighted that we have hit our target in 2022 to procure 100% renewable energy, having moved to a 100% renewable energy contract with our providers in September 2021. This means both our properties are now completely powered by clean electricity.

Every month, we track, monitor and report consumption across our operations. We have been reducing energy usage wherever possible, especially during the national lockdowns in 2020 and 2021. This included intentionally operating from a reduced number of floors, not heating our swimming pool and pool spa, replacing all our lighting with low energy LED lightbulbs, and installing PIR sensors. We also installed set timers on the fridges in our bar area, so they turn off automatically when not in use.

All employees undertake an environmental awareness course when they join us, which encompasses responsible energy usage. We also try to promote positive energy consumption practices among our guests. We have screens displayed around our properties promoting energy awareness and have implemented a ‘Switch Off’ policy, encouraging guests to switch off their appliances when not in use.

3.2 Water

In 2021, we essentially halved the water usage in our CitySuites Chapel Street property, from 12,328 cubic metres of water (m3) in 2020 to 6,294 m3 in 2021 — a 49% decrease in just one year. Our initiatives included turning off the water supply to our swimming pool and spa during the national lockdowns.

We also upgraded our water restrictors in both properties from yellow to blue, reducing the water flow to nine litres per minute — a 33% reduction across our basin taps and showers.

3.3 Waste

As single-use plastics, cleaning services and food waste are major contributors to waste in the hotel sector, we have pledged to reduce these wherever possible across our operations. We want to enforce a quality waste management programme, so guests have the same luxury experience — minus the unnecessary waste.

Compared to other hotels, we already use very little plastic in our operations. For example, all our luxury apartments provide complete guest amenities — cutlery, glasses and crockery — which drastically reduces the use of single-use plastics.

Some of the other small yet impactful switches we have made include:

• All bottled water removed from guest rooms
• Instilled a culture to refill toiletry bottles
• Only glass bottles are used in our restaurants
• Only eco-friendly coffee cups used in our restaurant and café
• Switched to washable laundry bags only
• Water machine in both gyms encouraging use of reusable bottles

We are proud to divert 100% of our waste from landfill — a milestone we certainly want to maintain in 2023. Properly segregating waste is also integral to the recycling process, which is why we have a tri-separator for waste on-site to segregate all general waste, paper, cardboard and glass bottles. We extended our segregation programme to include lights, ink cartridges and batteries, which are returned to a local recycling point.

We also expanded our efforts to address food waste. We now segregate all our food waste on-site before it is collected by our waste provider for recycling. We also recycle all our cooking oil. This helps alleviate the risk of pollution and it provides a green alternative to fossil fuels by producing biofuels. Our used cooking oil is collected by Olleco, whose facility can generate enough renewable biodiesel to fuel 1,632 heavy goods vehicles (HGVs) or 57,000 cars every year from all their clients.

Every month, we receive reports from our waste provider Freshwaste on both our properties. The waste report also delves into categories of waste, enabling us to effectively track each waste stream.

4. ESG Priorities, Initiatives and KPIs

The ESG Priorities and the associated initiatives and Key Performance indicators (KPIs) are focused on three areas:

1. Environmental
2. Social
3. Governance

Every year, we review our goals from the previous ESG Report and set new targets in line with our ESG priorities for the next 12 months. In Q2 2023, we will publish our third annual ESG Report with external assessment undertaken by Sustainable Advantage.

4.1 Environmental considerations:

• Lower our carbon intensity ratio by 5%
• Maintain 100% of waste diverted from landfill and reduce total waste by 5%
• Continue to procure 100% renewable electricity
• Explore onsite energy generation at CitySuites’ properties
• Assess impact of energy reduction initiatives against monthly consumption data

4.2 Social considerations

• Share supplier code of conduct and supplier questionnaire with at least 80% of our supply chain and begin to capture supplier ESG data
• Formalise CitySuites’ DE&I programme, supported by an employee Diversity and Inclusion council
• Develop a formal wellbeing policy and strategy and select wellbeing champions to reinforce initiatives
• Roll out a career development framework for all employees

4.3 Governance considerations

• Calculate gender pay gap and set out an action plan to reduce any inequalities
• Update ESG Policy annually

5. Review and updates

By implementing this ESG policy as part of our business, we will ensure that all our employees, guests, contractors and suppliers make a meaningful contribution to the quality of the local and global environment. This Policy has been communicated to all employees and will be communicated to any other interested parties working on our behalf. A copy will also be made available to any interested party upon request. This Policy will be reviewed annually to ensure that it remains relevant.

Date last reviewed: March 2023.

Modern Slavery and Human Trafficking Policy and Statement

Modern Slavery Act 2015

We are committed to ensuring adherence to the highest legal and ethical standards. As a group, we publish a statement describing the steps we have taken to ensure slavery and human trafficking are not taking place in our business or within our supply chain. This, together with our Modern Slavery and Human Trafficking Policy, reinforces our commitment to being a responsible business whilst addressing our own obligations under the Modern Slavery Act 2015.

Slavery and Human Trafficking Statement - Introduction from the Company Director

We are committed to combatting slavery and human trafficking in all its forms in our own business and in our supply chain. Select Property Group adopts a zero tolerance approach to any criminal offence. This statement is made pursuant to section 54(6) of the Modern Slavery Act and constitutes our slavery and human trafficking statement for the financial year 2023. This statement relates to all companies within the Select Property Group (Holdings) Limited group of companies.

Organisational structure

We are a global developer, retailer and operator of market-leading investment property brands headquartered in the UK. The ultimate parent company is Select Property Group (Holdings) Limited. The Group has over 300 employees.

Our business

Our business is organised into three business units:

• Vita Student provides purpose-built student accommodation;
• Affinity Living operates in the build-to-rent sector; and
• CitySuites provides a serviced accommodation offering primarily for business travellers.

Our supply chains

Our supply chains include design and engineering consultants, construction contractors, suppliers of furniture, fixtures and equipment, building maintenance/service contractors, professional service providers (such as lawyers and accountants), IT service providers, marketing and design agencies and recruitment agencies.

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free we have put in place a designated Modern Slavery and Human Trafficking Policy.

Our Modern Slavery Policy demonstrates our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Modern Slavery and Human Trafficking Policy

Due diligence processes for slavery and human trafficking.

Internal employees:
Employees are required to familiarise themselves with all policies and procedures to assist in the identification and prevention of such criminal acts.

External supply chain:
We fully expect that our direct supply chain members meet both legal and ethical standards in their daily operations while ensuring that compliance is managed appropriately across their own supply chain partners.

We have or intend to have in place systems to:

• Identify and assess potential risk areas in our supply chains
• Mitigate the risk of slavery and human trafficking occurring in our supply chains
• Monitor potential risk areas in our supply chains
• Protect whistleblowers

Supplier adherence to our values

We have zero tolerance for slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we intend to review our agreements and dealings with suppliers and contractors to ensure compliance with anti-slavery measures.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we intend to provide guidance and training to our staff. We will also encourage our business partners to provides training to their staff and suppliers and providers.

Our effectiveness in combating slavery and human trafficking

To make sure that we monitor our compliance with policy, we will use a number of key measures across our group of companies, including specifically completion of all statutory requirements to ensure the right to work within the UK. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending December 2023. All organisations who wish to secure contracts with Select Property Group and CitySuites will be required to produce a statement or policy on how they are tackling modern slavery and human trafficking.

This Policy has been approved on behalf of Select Property Group (Holdings) Limited.

Policy approved by
Gavin Bailey
Managing Director

Date last reviewed: July 2023
Next review date: July 2024

CitySuites welcomes people with disabilities and has developed this access statement to address some of the issues disabled people may face. Recognition has been given to include guests with impairments, which could include – mobility, sight, hearing, learning disabilities or any hidden impairment.

We aim to ensure all employees, guest and others who use the hotel are treated equally and according to their needs.

Pre-arrival

The accessible bus stop is located on Blackfriars Street, 100m from the residence. The nearest train station is Victoria Station which is approximately 350m from CitySuites.

Arrival

CitySuites main entrance is located on Chapel Street. There is a dropped kerb and access ramp for level access. Upon entry to the hotel step free access is available to the reception and all parts of the residence including all bedrooms via the two guest lifts.
There is always a member of staff available for any assistance which may be required.

Reception

The reception is staffed 24 hours a day. The reception desk has areas which are suitable for standing guests as well as a section to suit a guest in a wheelchair.
The registration card can be printed in large print if required.

Public areas

The Swimming Pool is located on the ground floor the gym is on the first floor which is accessible via guest lifts.
All floors of the hotel are accessible by lift, Ground to 16th Floor.
The lifts have audible enunciation, tactile buttons and a mirror at the rear. For guest safety, the lifts also include CCTV cameras.

Public WC

An accessible toilet is located on the ground floor in the pool area with level access. It is fitted with grab rails and alarm.

Guest bedrooms

All apartments have been designed with wide access corridors and wide entrance doors, low level light switches, power sockets by the bed.

Swimming pool

The pool is a uniform 1.2m deep with steps leading into the pool. CitySuites have provided a swimming pool hoist to enable wheelchair users to be lowered into the pool or spa.
An accessible toilet and shower are provided with grab rails, alarm and shower seat.

Gym

The Gym is open 24 hours a day, 7 days a week. The Gym is only open to guests staying at CitySuites. Personal Trainers must provide insurance and risk assessments to CitySuites management for our health and safety compliance.

General

Every effort will be made to ensure you have a comfortable visit. If you have any special requirements which are not listed above, do not hesitate to contact us.
For guests staying in the hotel, we will ensure you are fully aware of any emergency procedures and your requirements are taken into account.

Cleaning products and external company cleaning

At CitySuites we use cleaning products that are certificated to be effective against coronavirus viruses, bacteria and other airborne and blood-borne pathogens. All our external cleaning contractors also use products that carry the same certification.

1. Public spaces and communal areas – The frequency of cleaning and sanitising has been increased in all public spaces with an emphasis on frequent contact surfaces including, but not limited to, front desk, door handles, public bathrooms, apartment key cards, lifts and stair handrails, dining surfaces and seating areas. 
2. Guest apartments – Industry-leading cleaning and sanitising protocols are used to clean our guest apartments, with particular attention paid to high-touch items including television remote controls, toilet seats and handles, door and furniture handles, intercom, light switches, temperature control panels and flooring.

ISAAP Accreditation

At CitySuites, we work to ensure our policies and procedures resonate with the expectations of the guest and the accommodation buyer.

It is our continuous policy to ensure that we are regularly externally tested against independent standards specific to the serviced accommodation sector of the hospitality industry. We do this annually by engaging with ISAAP (International Serviced Accommodation Accreditation Process) to provide our accreditation and certifications.

In doing so, we can point to having regularly achieved and exceeded the benchmark standards for accommodation cleanliness, procedural hygiene, infection prevention and control, health & safety practices, accommodation quality and comfort, and legality.

Lobby and communal area

1. Antibacterial gel located on the reception desk near the entrance door. 
2. Employees encouraged to use an antibacterial gel at appropriate times throughout their shift.
3. All desk areas/computer terminals/telephones/PDQ machines and workspaces to be kept clean and wiped down regularly with an antibacterial surface cleaner. Encourage Contactless Payments.
4. All tables/chairs/door handles/reception desk and potential touchpoints to be cleaned using certificated antibacterial spray throughout the day and night.
5. All mop heads and cleaning cloths to be changed and washed (at 90 degrees) after finishing use in that specific area to reduce the risk of spreading the virus around the building or from apartment to apartment.
6. All apartment key cards to be cleaned with antibacterial wipes when handed back on check-out.
7. Guest personal hygiene request signage and antibacterial gel located inside both guest lifts.

Note:

• Additional housekeeping hours allocated to carry out extra cleaning of these areas and high touchpoints
• We have reviewed and reduced clutter in all these areas

CitySuites Pool area 

1. Fresh towels provided during opening hours. Separate storage for dirty towels.
2. All potential high touch areas cleaned using certificated antibacterial spray – before opening or closing and during operation.
3. Employees encouraged to wear gloves and wash their hands after handling dirty towels.
4. All mop heads and cleaning cloths will be changed and washed (at 90 degrees) after using in a specific area.
5. Toilets to be fully stocked with toilet roll and hand washing liquid. Carry out regular cleaning checks.

Note

• Additional housekeeping hours allocated to carry out extra cleaning of these areas and high touchpoints
• We have reviewed and reduced clutter in all these areas

CitySuites gym area 

1. Fresh towels provided with separate storage for dirty towels.
2. Antibacterial gel located at the gym entrance. Detergent spray and blue paper available for guests to clean equipment before use
3. All gym equipment and touch areas to be cleaned using certificated antibacterial spray throughout the day and night.
4. All mop heads and cleaning cloths to be changed and washed (at 90 degrees) after finishing use in that specific area to reduce the risk of spreading the virus around the building or from apartment to apartment.
5. Employees encouraged to wash their hands when arriving, handling dirty towels, after cleaning and when leaving this area.

Note

• Additional housekeeping hours allocated to carry out extra cleaning of these areas and high touchpoints
• We have reviewed and reduced clutter in all these areas

CitySuites corridors, corridor refuse areas and lifts

1. All potential guest touch areas (handles/lift rails/lift buttons/mirrors/tables/chairs/refuse area) to be cleaned using certificated antibacterial spray throughout the day and night.
2. Corridor carpet deep cleans to be carried out more regularly.
3. Lobby floor tiles to be mopped every day.
4. Guest Toilets (1st floor) - to be fully stocked with toilet roll and hand washing liquid. Regular cleaning scheduled to be carried out.
5. All mop heads and cleaning cloths to be changed and washed (at 90 degrees) after finishing use in that specific area to reduce the risk of spreading the virus around the building or from apartment to apartment.
6. Employees encouraged to use gloves and antibacterial gel as much as possible while operating in this area.

Housekeeping trolleys

1. Each housekeeping trolley is stocked with antibacterial gel and gloves.

• • Housekeepers encouraged to use gloves and antibacterial gel when entering, cleaning and exiting apartments.
  • Housekeepers encouraged to follow the personal hygiene measures suggested and equipment provided throughout their shift.

Embankment Kitchen

Table service only.

1. Employees encouraged to wash their hands or use an antibacterial gel at appropriate times throughout their shift.
2. Toilets to be fully stocked with toilet roll and hand washing liquid. Carry out regular cleaning.
3. All tables, chairs, door handles and potential customer touch areas to be cleaned using an antibacterial spray in the restaurant – opening, closing and during service.
4. Each table cutlery and condiments to be changed and cleaned after each customer sitting.
   
   • Transparent Perspex guard installed to separate the food area from potential customer contamination.
5. Coffee machine to be cleaned regularly throughout service.
6. Table salt and pepper dispensers to be cleaned regularly throughout service.
7. Cutlery (knife and fork) to be individually wrapped in a napkin and positioned on each table.
8. All menus to be wiped down after each table turn, using a certificated antibacterial spray.
9. All cutlery and serving implements to be washed in the dishwasher at 90 degrees. Serving implements changed every hour during service.
10. All computers terminals, telephones and workspaces to be kept clean and wiped down regularly with an antibacterial surface cleaner.

Note

• We have reviewed and reduced clutter in this area.