Policies
Reviewed and updated May 2024
Welcome
Caledonian Sleeper is committed to delivering a high-quality service to all our guests, making journeys easy and convenient for all. We want to provide a welcoming service and to ensure that the needs of our older and disabled guests are considered and fully met in all aspects of our service delivery, enabling them to travel independently and confidently.
This policy is supported by our Making Rail Accessible leaflet which provides a summary of the information provided here. It is available online and at our main departure stations.
This policy explains our approach to helping guests travelling on our trains. This includes for example:
- Passengers with visual or auditory impairments.
- Passengers with learning disabilities.
- Passengers whose mobility is impaired because of arthritis or other temporary or long-term conditions.
- Passengers with non-visible disabilities that might not be immediately apparent to other people.
- Older people.
- Passengers accompanying disabled children in pushchairs or wheelchairs.
- Passengers with a disability who need help with luggage.
The purpose of this policy is to help you plan your journey, understand what services we offer and how we plan to meet your expectations when travelling with us.
We review this policy once a year to ensure that all the information provided to you is up to date. We work closely with our Accessibility Panel as part of this review.
This version of the Policy was developed in conjunction with our Accessibility Panel, Transport Scotland, and Scottish Rail Holdings.
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Our Guests
In the railway industry, customers are generally referred to as passengers. However, as we also deliver a hospitality service, we consider our customers to be our guests and use this term in this policy.
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On board Hosts
These are our staff who will greet and support you onboard our trains. They will operate the onboard ramps for you and assist you with luggage if needed. On each service, there is one train manager, one team leader and up to three onboard hosts.
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Guest Service Centre
Our team of Guest Ambassadors work in the Guest Service Centre. Their job is to help you plan your journey, book tickets, and give you any information about accessibility features so you can make informed choices.
Commitments to providing assistance
We are committed to participating in Passenger Assist, the nationwide reservation system for booking assistance for train travel.
Our Guest Service Centre responds to requests for Passenger Assist through email, phone calls and Passenger Assistance App, and answer any questions as part of the booking process.
Our Guest Ambassadors are trained and experienced colleagues who understand our services and routes. Each day, our Guest Service Centre reviews all Passenger Assistance reservations for the Caledonian Sleeper made through Passenger Assist to make sure they have been made correctly and that appropriate assistance is in place onboard and at the stations we serve. If we are not able to offer passenger assistance due to the times or location of our service, our Guest Ambassadors will work with our guests to arrange a suitable alternative. We commit to providing sufficient resources to maintain and improve the standards of Passenger Assist.
You can book two hours before the train is due to leave its originating station.
You do not need to book assistance but given the unique nature of our services, we encourage you contact us in advance to discuss your access needs.
We do not manage any stations. All stations we stop at are managed by different train operators, who are responsible for staffing. All bookings are made through Passenger Assist which station operators use to check what assistance is needed at their stations each day. Each station operator has different policies on the assistance they provide and at what times. We can give further advice on this for any guest’s journey through our Guest Service Centre, including arranging meeting points for your assistance.
You can download the Passenger Assistance app for iOS and Android here.
On our services, we are committed to assisting our guests on and off our trains and providing any help you need during your journey when this booked in advance through Passenger Assist.
The times that each station is staffed are listed on the relevant station page of the National Rail Enquiries (NRE) website and on the Accessible Travel page on our website. Our Guest Service Centre can look up this information for you if required.
When you book assistance through our Guest Service Centre our team will review the accessibility of the stations you plan to use and check that it meets your needs. If you would prefer, we can provide this information by post on request.
When assistance has been booked in advance, we are committed to helping you off the train as soon as possible on arrival at your destination, and within a maximum of five minutes where reasonably practicable. If assistance is being provided by station staff, our on-board hosts will ensure this is carried out as planned or will help you off the train if there is a problem.
If you have not booked assistance and the station is not staffed on arrival, our on-board hosts will help you on and off the train. You will need to be on the platform when your train arrives and get the attention of an onboard host who will always step onto the platform and look for guests waiting to board at each station that our service calls at.
If the station is staffed when you arrive to board one of our services, these staff will help you within the station. If you have not booked assistance in advance, the station staff will help you if they can. As we do not operate these stations, we cannot control the delivery of this, but we do work with these operators to find ways to improve our guest experience. We have an agreement with station operators, so if for example, your destination station is staffed, we will phone them directly so they can be ready to give you additional support when you arrive.
There are ramps at all of the step-free staffed stations that we serve. We also have portable ramps on all our trains which our on-board hosts will use if they are helping you on or off the train. A ramp will always be available on dedicated coaches whether you have booked assistance in advance.
Whilst we do not operate any stations, we know that our service will often call at stations during the night when stations may not be staffed. We will explain this to you as part of the process for booking assistance, so you know what to expect.
We work closely with the operators of stations at which our services call to improve the experience of our guests. If you book assistance through Passenger Assist, you can plan assistance for a journey which involves more than one operator all in one booking. The person making your booking will check you have enough time to make connections.
As we do not operate any stations, our on-board hosts are unable to assist you beyond the platform. In addition, we cannot control the information which operators share about their station facilities. The best place to find information on any temporary limits on accessibility is the station page of the NRE website – you can access this at www.nationalrail.co.uk/stations_destinations or contact us and we can check for you. In all cases, we will check station accessibility if you book assistance with us through our Guest Service Centre, as well as verifying all bookings made through the Passenger Assistance App. If you are travelling with luggage, we are happy to help you. However, we only know you need help if you have booked the service through Passenger Assist. If you are not able to book, we will offer help whenever we can but cannot guarantee it. There is no charge for helping with your luggage.
Please consider the weight, size, and quantity of your luggage as there is limited space available on board. Items of luggage must also be a safe for our staff to lift. If possible, please only have:
• one item of hand luggage (that you must be able to hold on your lap if necessary); and
• up to two items of luggage no bigger than 30cm x 70cm x 90cm.
Everyone needs a reservation to travel on the Caledonian Sleeper, in addition to your ticket. You will be assigned a room or seat as part of this process.
There is a dedicated wheelchair space in our seated coach. Guests are allocated a coach based on their destination as the train divides along the route. Priority for the wheelchair space is given to guests who have reserved the space in advance.
We welcome guide and assistance dog on our trains. Please let an on-board host know how we can make your dog comfortable by providing water for example. If you are travelling with us in seated accommodation, please contact our Guest Service Centre in advance to reserve the seat next to you to enable your dog to sit safely at your feet. There is no additional cost for this booking. We can also upgrade you to a room, free of charge, if one is available.
View our pet policy here.
Our leaflet ‘Making Rail Accessible is available:
• in print at our main departure stations that our services leave from.
• on our website as an accessible PDF.
This document is available:
• on our website; and
• in print at all our main departure stations that our services leave from
• by post upon request free of charge. We will send it within seven working days.
Any posters or signage at stations relating to our services are at a height which means they can be easily read by wheelchair users.
Although we do not operate any stations, we are committed to regularly seeking the latest information about accessibility features of stations we call at. We will keep this updated and make this information available:
• Via our Guest Service Centre which is online 24 hours a day via our live chat
• on our website https://www.sleeper.scot/ and
• National Rail Accessibility Map is used by our Guest Service Centre
• Find a Station | National Rail is used by our Guest Service Centre
• by post on request within seven working days free of charge.
We provide a comprehensive range of information about the stations our services call at including the availability and accessibility levels of toilets, waiting areas, staffing hours and help points. We continually work with the station operators to source all the information we need about their stations to ensure it is always accurate. We are committed to verifying the accuracy of the information contained in the guide as part of the annual review of our Accessible Travel Policy. In the meantime, we will continue to keep our website updated.
Because the Caledonian Sleeper service runs during the night, we do not make onboard announcements except in an emergency. If you wish to receive audio or visual updates during the journey (for example to let you know that you are approaching your stop), you can request this from our onboard hosts when you board and they will speak to you at the appropriate time, giving you sufficient time to leave the train.
If your journey is going to be disrupted (for example due to planned engineering works) our Guest Service Centre will contact you in the way you said you would prefer when you booked assistance. If you would find this useful, please get in touch and ensure we have your correct contact details. We will explain the expected impact of the disruption and discuss the options for alternative arrangements.
If you are staying in a room, you can request a wake-up call or be notified of delays if you wish. Staff will visit your room personally if the in-room phone is inaccessible. The same applies to guests in our seated coach. Our seated coaches have screens which give information about stopping times.
We strive to provide you with a comfortable and relaxing journey. If you experience a problem on board our trains, please tell a member of staff who will try to find a solution to minimise any inconvenience. If there are any problems with our on-board accessibility features, such a serious fault with an accessible room you have booked, we will contact you via your preferred method of communication.
You can get all the information you need to plan and prepare for your journey with us from our Guest Service Centre and by visiting our website. We have designated information points at most of the stations we call at which provide real-time departure information, in addition to customer information screens. There are also Help Points at the stations which you can use 24 hours a day for timetable information.
If you book assistance, we will let you know where the meeting point is. Larger stations usually have a designated point (e.g., a booking office or mobility assistance lounge) but if there are no station staff on duty, we will usually agree to meet you on the platform as the train arrives. The meeting point will be confirmed in your Passenger Assist booking confirmation.
If there are no staff at a station we stop at, the ticket gates will be left open.
All of our telephone services, for example the Guest Service Centre, include a text relay service.
We currently use Next Generation Text.
We have worked with Shaw Trust to improve the accessibility of our website. The website has been tested by users who are disabled and use assistive technologies such as JAWS, NVDA screen readers, Dragon voice activation software and Zoom Text magnification. We have changed our website to WCAG Level AA standards and aim to have this fully accredited in 2024.
Note: this could not happen in 2023 due to the transfer in 2023. Our new website will be live in 2024.
We have a dedicated page on our website called “Accessible Travel” which can be accessed from our homepage. This page includes the following, in HTML format:
• a clear and simple summary of Passenger Assist.
• the contact details to book Passenger Assist and purchase a ticket.
• information on discounts such as railcards.
• a list of our on-board facilities, particularly features within accessible rooms.
• a link to download our Accessible Travel Policy and details of how to get this in alternative formats.
• information on how to make a complaint and seek redress if your booked assistance was not provided.
The easiest and cheapest way to buy a ticket to travel on the Caledonian Sleeper is from us directly. At the same time, we can also address your access needs and book assistance if needed. When you book tickets with us, we will send you an e-ticket and confirmation by email. You can either show this to staff on your phone or print them out before you travel. If you cannot do this, we can post your ticket to you.
You can also use a valid national rail ticket provided you also have a reservation for the Caledonian Sleeper. You can buy national rail tickets from ticket machines at stations, which can apply discounts for Disabled Persons Railcard holders. These tickets must be valid between stations served by Caledonian Sleeper for part or all of your journey. You also need to make a reservation to travel on the Caledonian Sleeper service through our Guest Service Centre. Unless you book a room supplement, a ticket and reservation allow you to travel in seated accommodation only.
You cannot buy or collect Caledonian Sleeper tickets from station ticket machines. We will send you an e-ticket by email to present on your phone or to print at home if you prefer. We can also send your ticket by post if you prefer.
If you are a disabled guest and unable to purchase a ticket before your journey, you can buy one on-board without penalty with any eligible discounts. However, there is limited availability for our wheelchair spaces and accessible rooms, so we recommend booking in advance.
We keep this policy under regular review and consult with our Accessibility Panel.
We want to welcome as many disabled and older guests as possible. However, we know that there are additional considerations for safety and comfort when travelling on an overnight service. We therefore take care to think through the consequences of any breakdown in a disabled or older person’s ability to access the service in the way that was expected.
As part of the journey planning and assistance booking process our Guest Service Centre, will talk through:
• Accessibility of the stations you plan to use.
• Accessibility of our trains including rooms, toilets, and shower facilities; and
• Staffing levels at the stations you plan to use.
When booking your journey, it might become apparent that we need to arrange alternative accessible transport for you because you wish to use a station that is inaccessible to you (for example, because of stairs). Alternative accessible transport will, at no extra cost, take you between the inaccessible station and the nearest or most convenient one that is accessible to you.
When we organise rail replacement services because of planned or unplanned disruption, we use suppliers to coordinate vehicles that meet your needs. We will always ensure there is an accessible option for you. For this reason, we will discuss your needs before booking rail replacement, giving you the added choice to re-book your travel with us or explore other travel options based on your needs.
We are aware that travelling long distances by road or staying in a hotel might be difficult for a disabled or older person. For this reason, we encourage you to contact our Guest Service Centre to discuss your needs in advance. We aim to be open and transparent, enabling you to make informed decisions.
Accessible taxis are usually unable to carry scooters and so we cannot guarantee the arrangements set out above can be offered to scooter users. If you are a scooter user, we will explore and discuss with you what options are available. This will include understanding if your scooter can be folded and whether your scooter can be safely secured in the vehicle. If neither of these options are possible, we will work with you to look at alternatives such as supporting you to travel home (securing your scooter safely overnight) and arranging transport for you to collect your scooter the next day or as soon as possible.
Like most trains across the UK, we can carry wheelchairs, scooters and rollators which are no larger than 70cm x 120xm and a combined weight of guest and wheelchair/scooter of 300kg. Guests are asked to check the size and weight before travelling to avoid disappointment.
Scooter users can stay in the scooter if they wish but may prefer to transfer to a seat.
Please note the restrictions in the section above above regarding alternative transport for scooter users.
We understand that disruption to facilities and services can have a significant impact on accessibility and on the confidence of disabled people in rail travel. When disruption happens, we do everything we can to ensure that, wherever possible, you are able to continue your journey.
In cases of planned disruption, we do everything we can to find and use accessible rail replacement vehicles. Given the rural locations of our services and unsocial hours of operation, sometimes we depend on accessible taxis to meet the needs of our guests.
We do not manage any stations along our route, so we are unable to escort guests to connecting trains. If our train is moved to a different platform at short notice and you are due to be met by staff at that station, we will make sure you are helped off the train in time and wait with you until the staff member arrives.
Our onboard hosts and staff who check and maintain our trains report any serious faults in our accessibility features. In the absence of a short-term solution, we will contact any disabled or older guests before they travel to explain and discuss options. We will also inform the Guest Service Centre.
Where rail replacement services are not accessible for you, we will organise alternative accessible transport suitable for your needs (see Section above).
Where you have booked assistance for a journey that because of disruption no longer meets your needs, our Guest Service Centre will contact you by your preferred contact method. They will tell you about the anticipated disruption and discuss what alternative arrangements might need to be put in place. This will be provided at no additional charge. If you would find this useful, please get in touch and ensure we have your correct contact details.
If you are already travelling with us when unplanned disruption occurs, our on-board hosts will discuss this with you and arrange how to get to you to your destination. If you have not yet boarded the train and are waiting at an unstaffed station, please contact us for more information via an Information Point or Help Point.
We understand that you may need additional assistance in an emergency. All of our on-board staff are trained in these procedures, including evacuating the train. In most cases, it is safer to stay on the train if there is an incident. However, our onboard hosts will help all guests off the train (including those with mobility issues) if there is risk of danger to life. We will then also organise onward travel for you and accommodation if appropriate.
We do not operate any stations. However, we understand station accessibility may be a key issue in planning your journey and so our Guest Service Centre can provide you with the information you need.
Accessible shower facilities
On board our trains, there are only en-suite shower facilities in Club rooms. There are no showers facilities provided for guests in our seated coach or accessible rooms.
Whilst there are no accessible shower facilities on board our trains, guests staying in accessible rooms can use the accessible shower facilities at London Euston, Glasgow, Aberdeen, Fort William, Dundee, Leuchars, Perth, and Inverness free of charge. These are gender-neutral facilities. Our Guest Service Centre can provide further information.
Left Luggage
There are staffed left luggage facilities with step-free access the following stations:
- Glasgow Central: Monday to Saturday 6am to midnight. Sunday 7am to midnight
- Edinburgh Waverley: Monday to Sunday, 7am to 11pm
- Inverness: Monday to Sunday, 7am to 9pm
- London Euston: Monday to Sunday, 7am to 11pm
Parking
You can find information about parking facilities, including Blue Badge Bays, on our website, or on the National Rail Accessibility Map.
If you experience a problem, please let our onboard hosts know so we can try to resolve the issue immediately.
When assistance has been booked in advance, confirmed, and was not provided, please let us know and we will investigate this thoroughly. When you contact us with any complaint (by phone, post, or email) we aim to respond fully in 10 working days. If there is a reason, we cannot do that, we will keep you updated until we can respond.
After we have investigated the matter, we will explain to you why assistance was not provided and what steps will be taken to ensure it does not happen again. We may also offer compensation, such as a full or partial refund. Alternatively, or additionally, you may want reassuring that our staff training has been updated to help stop the issue happening again. This will be determined on a case-by-case basis to ensure we do the right thing.
We will respond to any claim about assistance which failed if you were travelling on, or due to travel on, one of our train services. If you booked assistance with us for a journey to travel with more than one operator (including our services) you only need to make one claim. We will coordinate the response for you unless the bulk of the failed assistance was provided by another operator, in which case they may respond to you directly. If we make arrangements for the claim to be passed to another operator, we will ask your permission first.
Strategy and Management
We actively seek feedback from our guests and our Accessibility Panel as part of our planning processes. We understand that the unique nature of our service makes it a convenient and appealing option for disabled travellers. We strive to ensure that our service is accessible to all guests and actively seek to improve our facilities.
We consider accessibility in everything we do and recognise this as part of continuous improvement. Our Guest Experience Director has overall responsibility for our Accessible Travel Policy.
Our Guest Experience Director ensures that accessibility is a central part of our business plans and of the planning stage of all relevant major projects. This involves leading a culture of valuing inclusion in all areas of the business. We consciously lead accessibility from the Guest Experience division of the business because we understand that standards must go beyond the minimum and consider the whole experience of a disabled guest.
In terms of implementing our policy, the following colleagues report to the Guest Experience Director:
• Head of Guest Experience Service Delivery
• Guest Service Centre Manager
• Head of Service Delivery
• Head of Operations
All our managers and staff receive disability awareness training which includes ensuring they understand their role in fulfilling this policy. Our onboard hosts, who provide assistance and information to our older and disabled guests every day, are actively encouraged to suggest improvements. These are recorded and reviewed by our Guest Experience Director personally.
Our Guest Experience Director champions accessibility within our business and ensures all senior leaders within the business are fully aware of the requirements of their own teams in fulfilling our accessibility commitments and obligations.
To ensure the standards and commitments in this policy are consistently achieved, we have monitoring and evaluation mechanisms in place.
We record all feedback, including complaints and compliments, received from our guests about accessibility. These may relate to the journey planning process (including booking assistance) or the journey experience. Our Guest Experience Director reviews these personally.
We also aim to monitor:
• the number of ticket sales for our services using a Disabled Persons Railcard (DPRC), although we need to improve the mechanisms through which we collect this information.
• the experience of older and disabled people using our trains through survey questions.
• assistance booked through our Guest Service Centre and how many rooms are booked for accessibility; and
• Passenger Assist bookings made by guests and delivered by staff (whether booked or not).
To enable the Office of Rail and Road (ORR) to independently monitor our progress we commit to sharing our performance data. As part of our annual review, we provide the ORR with details on key actions we are taking in order to improve our performance.
Access to the stations we serve, and the facilities and assistance available, varies considerably. Most of the stations that we serve were built in the 19th century when inclusion of disabled people was rarely considered. Key improvements have been made at a number of stations across the national rail network and we will work with station operators to continue to improve the stations we serve. We have processes and policies in place to combat inconsistency and maximise a disabled guest’s experience, such as providing assistance and/or alternative accessible transport.
Any improvements we make will meet the persons of reduced mobility technical specification (PRM TSI) and the Joint Code of Practice. If this is not possible, we will apply for derogations against the PRM-TSI and/or dispensations against the Joint Code of Practice, after every effort has been made to comply with the requirements.
In 2023, we opened a new, dedicated Caledonian Sleeper lounge and London Euston, located of the platform from which our services depart and arrive. The new lounge is fully accessible. We have also re-introduced access to the LNER lounge at Edinburgh Waverley. This lounge is fully accessible.
In 2024/25. We plan to make the following improvements:
• Fully review and improve our website. We have worked in conjunction with our Accessibility Panel and the Shaw Trust to ensure that the improvements meet particular needs.
• Make improvements to the shower facilities in our Inverness lounge which are not fully accessible at present.
• Review our Accessibility and Equality staff training provision.
• Create a staff accessibility forum with a mix of people who work for Caledonian Sleeper.
We have a shared budget with Scotrail for minor work to improve access at stations. Each year, our Guest Experience Director, working with our new Accessibility Panel, plans how we will spend this in consultation with the Disabled Persons Transport Advisory Committee (DPTAC), Transport Focus, Network Rail and the relevant train operators managing the stations. We will also consult with Transport Scotland on any enhancement opportunities.
We have an Accessibility Panel who meet at least twice a year. The Panel is comprised of:
• Guests who have travelled on our services and potential guests who might have identified barriers to using our services.
• People who have experience of receiving assistance from us to use our services.
• People with visible and non-visible impairments; and
• People who experience a range of access barriers (related to a range of impairments and to characteristics such as age, income, and confidence levels).
The purpose of the Accessibility Panel is to be an independent sounding board for us on accessibility issues, to critique our plans and propose ideas for improving the experiences of our disabled and older guests.
They also help us to prioritise our investment plans and advise on how to raise awareness of assisted travel by signposting us to influential organisations in their networks.
Accessibility consultants with lived experience of disability are commissioned to regularly review our progress and provide expert advice in improving access to our older and disabled guests.
Our Guest Experience Director works with and involves groups representing disabled people and other stakeholders such as Mobility Access Committee Scotland.
We address accessibility issues as they arise during our regular stakeholder meetings with regional transport partnerships in Scotland, local authorities, councils and community rail partnerships and interest groups. We also invite our guests and interested stakeholders to give us feedback at our ‘Meet the Manager’ events every three months, by contacting our Guest Service Centre, or on our website.
All of our onboard hosts and colleagues in our Guest Service Centre receive disability awareness training when they start working for us and complete an e-learning every year to refresh their knowledge. every year. A key outcome is for staff to communicate clearly and feel confident to respectfully ask guests with a range of access needs and impairments how they can best meet individual needs. Staff also learn about key equipment such as ramps and in-room intercoms.
The training also includes guidance on assisting guests with visible and non-visible impairments. We provide an annual report to Transport Scotland and ORR on the training our staff have received.
Topics covered in our training packages include:
• Understanding disabled people’s everyday challenges.
• Equality legislation.
• Defining disability.
• Recognising guests who need assistance.
• Rail regulatory framework.
• Passenger Assist.
• Communication.
• Station accessibility.
• Providing safe assistance.
Please see National Rail Conditions of travel
Caledonian Sleeper Limited (“CSL,” “we,” “us,” “our”) is a company incorporated in Scotland (Company Number SC328825) and a subsidiary of Scottish Rail Holdings Limited, which is owned and controlled by the Scottish Ministers.
On 25th June 2023, CSL took over the operation of the Caledonian Sleeper overnight passenger rail services between Scotland and London. Prior to 25th June 2023, the Caledonian Sleeper service was operated by a private operator, Serco Caledonian Sleepers Limited. This statement therefore covers the period from 25th June 2023 to 31st March 2025.
This statement is published by CSL in accordance with our obligations under Section 54(1) the Modern Slavery Act of 2015, which requires any organisation with a global annual turnover of £36m or above and operating in the United Kingdom, to produce an annual Modern Slavery and Human Trafficking Statement.
CSL’s statement details the steps we have taken since 25th June 2023, to the date of this statement, to ensure that modern slavery is not taking place within any part of our business or supply chains. It sets out the steps that CSL has taken during this period to manage risks of Human Trafficking, Slavery, and Forced Labour in CSL’s organisation and supply chains.
We will publish an updated Human Trafficking, Slavery and Forced Labour Statement in respect of each financial year. Any queries in relation to this should be addressed to:
Legal & Compliance Team
Caledonian Sleeper Limited
70 Wellington Street
Glasgow
G2 6UA
Our Commitment
CSL is committed to:
- Operating to the highest social and ethical standards and fostering an open, and transparent culture.
- A zero-tolerance approach to Human Trafficking, Slavery and Forced Labour. At a senior level, our Executive Team strongly supports and communicates the aims of the Modern Slavery Act 2015 to all business areas, as well as our zero-tolerance approach to Human Trafficking, Slavery and Forced Labour.
- Taking all reasonably practicable steps to ensure that Human Trafficking, Slavery and Forced Labour have no place in our business, processes, and supply chains.
- Supporting our people to understand the impact, risks, and identifiers of Modern Slavery, and for those with contract management roles to uphold our standards.
- Working with consultants, contractors, suppliers, and third-party representatives, who work on our behalf, to ensure they share and align to the same standards, so that Human Trafficking, Slavery and Forced Labour risks, are identified and managed proactively.
Our Organisation, People and Work Environments
Our Organisation
CSL operates overnight rail passenger services between 5 Scottish Destinations (Glasgow, Edinburgh, Fort William, Inverness, and Aberdeen), and London. We operate 10 services each evening, 6 nights a week, with many of our front-line employees working overnight hours. This includes both city and remote environments, in all weathers and during times of disruption on the railway network.
Our people and our guests travel from a range of major Scottish cities and remote rural locations to London; one of the busiest tourist and business cities in the world, with links to other national and international transportation.
The nature of our services means that we have employees in Guest Experience, Operations and Shunting, as well as our Guest Ambassadors in Inverness and Glasgow. These teams work through the day and night to ensure that our guests can be accommodated on our trains, which depart in the evenings and arrive at our destination stations the following morning.
We offer a range of accommodation types, from seated travel to en-suite twin or double rooms and accessible rooms. All of our trains feature a Club Car dining restaurant for our Club and Caledonian Double guests, who are also able to use our lounges prior to their departure and upon arrival.
We work with other train operators, rail replacement providers, Network Rail, the Office of Rail and Road, the British Transport Police, and partners within the rail industry (including those in engineering, catering and hospitality sectors) to make sure that our services keep our guests safe and comfortable during their overnight travel.
Our People and Working Environments
We employ over 280 people in the areas of Guest Experience, Operations, Finance, Marketing and supporting staff functions.
Our people are employed in a range of working environments, including on-board our trains, in depots operated by third parties, offices and in our lounges, many of which involve them working through the night.
We are a non-discriminatory employer and have adopted an Equality Policy which aims to eliminate unfair discrimination, harassment, victimisation and bullying and promote diversity, and equal opportunity. We also operate in accordance with our Whistleblowing and Anti-bribery policies. Staff training is provided in all of these areas.
Our zero-tolerance approach to modern slavery and trafficking features in our employment practices. We articulate this in our recruitment materials and processes.
We conduct thorough due diligence on suppliers and recruitment agencies to ensure they comply with antislavery laws and ethical labour practices. We ensure that all recruitment processes are transparent, including clear communication of job terms and conditions. Additionally, we have established clear channels for candidates and employees to report concerns about modern slavery or exploitation without fear of retaliation, and we have implemented mechanisms for monitoring our compliance in relation to slavery and trafficking risks.
When recruiting our people, whether on a permanent or temporary basis, our processes are designed to ensure we maximise the possibility of detecting any signs of slavery, human trafficking or forced labour. We also have in place robust approaches in terms of verifying proof of identification and entitlement to work in the UK. Our lowest pay band is consistently higher than the Living Wage standards of payment.
To complement this Modern Slavery Statement, we will be launching e-learning to our employees to raise awareness and so that our people are equipped to recognise signs of the serious issues of modern slavery and human trafficking, and so that all staff can understand their role in preventing exploitation. This is incorporated into our core Learning Management System (LMS), which is available to all employees. We will be introducing a reporting system for our front-line staff as well as specific training for our staff who engage in contract management of suppliers.
CSL is committed to ensuring that its guests, people and third parties are treated fairly and with respect, as well as being valued irrespective of disability, race, gender, health, social class, sexual preference, marital status, nationality, religion, employment status, age or membership or non-membership of a trade union. We operate a Company Council, and we liaise with relevant union organisations, to ensure our people are heard in respect of their employment rights.
We ensure that employees have a platform through which to express opinions or grievances, and how to seek help and support.
We recognise the importance of two-way dialogue with our employees and to facilitate this we have formal mechanisms such as ‘Time with Your Manager’ sessions and an internal social media tool, Viva Engage, to allow colleagues to communicate with each other and ask questions.
All staff are able to access an Employee Assistance Programme, and we offer our people the ability to access private healthcare benefits. Several of our employees form an Incident Care Team to manage and respond to any emergency issues that arise. This can include being on-call and making sure the safety of our staff and guests is paramount.
For our on-board and other front-line employees working overnight, we support the potential risks of travel and working hours fatigue, by providing them with hotel day-let accommodation when their job requires them to arrive at a destination city away from their home address. Our rota arrangements are also set up to manage fatigue where front-line staff have completed a number of overnight shift patterns.
Compliance
CSL’s Legal and Compliance Team is responsible for:
- raising awareness about the societal impact of modern slavery and our role (as a business and a public authority) to tackle it.
- supporting our on-board employees to identify and respond to vulnerabilities of human trafficking on our train services.
- helping our Commercial and Procurement Team and Contract Managers to manage risks of modern slavery and human trafficking within our supply chains.
In 2025, CSL became a Corporate Partner of Scotland Against Modern Slavery (SAMS), a forum for the business community to share good practice, intelligence, to support victims and to be prepared for changes to Modern Slavery legislation. Our Legal and Compliance Team has an appointed SAMS Ambassador to represent CSL and participate with the Scottish Government’s Human Trafficking and Exploitation Strategy Team.
This will enable CSL to exemplify best practice and generate awareness of modern slavery, both within our own business and externally to our stakeholders and other businesses across Scotland.
Procurement
We have a supply chain of over 200 suppliers operating mainly in the UK, who deliver a range of goods and services across our business.
This includes suppliers of the following types of services:
- Rolling stock and maintenance
- Track access and provision of traction services
- Ticketing and retail systems
- On-board catering
- Cleaning services, linen supply, and hotel stock provision
- Water quality treatment
- Property services and maintenance
- Marketing services
- Uniforms
- IT and finance systems
- Engineering servicing
- Branded merchandise made available on our online souvenir shop.
CSL’s Commercial & Procurement Team use internal processes and governance to ensure compliance within our procurement obligations as a public body. This includes us working towards industry best practice frameworks, so that we can achieve the best commercial outcomes with our outsourcing and third-party relationships, as well as complying with our contractual obligations, legal and regulatory requirements.
Our Procurement Policy includes a suite of documents relating to procurement ethics and business conduct. These form an important part of our commitment to creating a better and more sustainable future, including environmental and social standards. We expect our suppliers to actively support and align to our policies, values and principles.
At the outset of working with our suppliers, it is essential to ensure they share our commitment to minimise Human Trafficking, Slavery and Forced Labour risks. Suppliers that are invited to supply goods and services to CSL must demonstrate how they ensure that these issues do not take place in their own supply chains, and how they address their legal obligations. Their responses are evaluated as part of the procurement process.
Our Procurement & Contracts Team work with our Business Supplier Managers to procure all goods and services and manage our ongoing relationships with suppliers. Our commitment to conducting business ethically and responsibly is reinforced throughout various company policies, and good practice activities, and we require our suppliers to adhere and align to our Supplier Code of Conduct.
Our Commercial Contract Terms
At the outset of becoming a public body in June 2023, CSL took external legal advice to ensure the application of the Modern Slavery Act 2015 is fully embedded in our culture and features in our standard Terms & Conditions. Our commercial contracts require our suppliers to:
- comply with all applicable laws.
- have in place and manage their own Modern Slavery and Human Trafficking policies and procedures.
- provide notifications, reports, and certification about their compliance with Modern Slavery laws.
- ensure that any of their sub-contractors relevant to CSL will comply with our Modern Slavery requirements.
- participate in the conduct of supplier audits.
We are working towards ensuring these types of clauses are consistently included in all of our new contracts and with suppliers aligning to the principles and requirements in our Supplier Code of Conduct.
Audit, Assurance and Risk Management
During 2025, we plan to update and include into our audit processes, rigour, and formality, in relation to our scrutiny of supply chain ethics. To support this commitment, during 2024, CSL has provided certified Auditor and Lead Auditor training to seven employees in key roles throughout the organisation, so that they are qualified to conduct external supplier and internal assurance activities for the organisation. This certified training in Continuous Quality Improvement (CQI) and International Register of Certificated Auditors (IRCA) is recognised by ISO Standards.
By having a group of employees with experience in different disciplines, attain formal qualifications in auditing quality management systems, CSL can review supply chain ethics as a specific term of reference in our supplier audits.
As a provider of overnight hospitality as well as transport, we utilise a range of suppliers, some of which are likely to have a different risk profile for modern slavery risks, than other suppliers to the rail industry. For instance, our supply chain for food and beverages, bed linen towels and mattresses, laundry, cleaning, and presentation services might typically have a higher supply chain and trafficking risk profile than other suppliers of engineering and IT services.
Although this may mean that our audit and assurance of those suppliers might flag a higher likelihood risk for us to manage and scrutinise, our qualified auditors will conduct and expect the same high standards of enquiry for all our suppliers.
CSL identifies and manages risks to the delivery of our key objectives, business plans and targets, through our Risk Register. The Risk Register is maintained and regularly reviewed. Senior managers are actively involved in the identification and management of risk and participate in regular reviews of risk to our business operation relating to our suppliers and their supply chains.
Identification and Support with Suspected Trafficking
As a provider of overnight cross-border transport, its vital to support out front-line staff to identify, report and respond to instances of suspected human trafficking and transportation of workers. This is especially important given our night-time operation and the city and rural locations that we serve. We recognise that our role in responding to suspected trafficking on our train services must ensure the correct reporting of incidents, as well as supporting individuals travelling on our trains, and supporting the wellbeing of any employee responding to an incident.
Our staff training will help our people to be alert to risks associated with people being transported, and how to seek help from other agencies, given this would be a delicate issue for staff to confront without specialist support.
We are supported in this effort by the British Transport Police, and we participate in the Rail Guardian scheme; a UK wide initiative and application to keep people safe from harassment on the railway network. It is a safe way to support harassment victims in a discreet and sensitive manner. All of our on-board staff carry devices with a link to the Railway Guardian application and are trained in how to use it.
During 2025, CSL will develop its reporting processes for our onboard teams to use.
Key Actions for the Coming Year
CSL has committed to:
- Implementing an annual ‘Core Compliance’ requirement as part of a wider Supplier Relationship Management (SRM) process. This will include specific questions on the suppliers ongoing compliance to the contract including Human Trafficking, Slavery and Forced Labour obligations, and how the supplier will evidence this on request.
- Reviewing our policies to consider alignment with relevant management system standards.
- Evaluating the benefits of joining industry schemes such as the Railway Industry Supplier Qualification Scheme (RISQS) Modern Slavery working group.
- Evaluating the benefits of engaging with Chartered Institute of Procurement and Supply (CIPS) to identify any gaps, develop an action plan and mitigate these with appropriate training.
- Understanding how the Supply Chain Sustainability School can provide guidance and training to key suppliers on Modern Slavery.
- Undertaking CIPS Ethical Procurement and Supply eLearning and assessment.
Raising Awareness and Supporting Our People
As well as launching our e-learning we will promote the importance of our modern slavery compliance efforts on our online employee intranet site, The Platform, and, in due course, wider publication of our zero-tolerance commitment on our social media channels.
CSL will monitor the effectiveness of our compliance to this statement on an ongoing basis and take necessary steps to address any instances of Human Trafficking, Slavery and Forced Labour.