Thomas Cook review: The 49 recommendations in full

Justin Rose’s independent review of Thomas Cook’s health, safety, welfare and crises management practices made 49 recommendations.

Monday, 2nd November 2015, 3:18 pm
Christianne Shepherd, seven, and her brother, Robert, six, who died after a faulty boiler leaked gas into their bungalow in Corfu in October 2006.

Section 1: Health & Safety

1.1 The recommendations contained in the recent audit of the Group Health & Safety Systems with action plans already in place should be implemented at pace now that they are agreed.

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1.2 A formal review of the success of the SGS contract should be conducted to coincide with the 2nd anniversary of its commencement. The Thomas Cook Group must consider a significant increase in the budget allocated to this activity. The focus in particular should be on deeper audits (rather than more frequent) and an extension of the activity to a wider group of hotels.

1.3 In support of this the Thomas Cook Group should increase significantly the internal resource allocated to health & safety. The focus in particular for this extra resource should be preparation for the legal changes which will likely require wider checking and the creation and delivery of new colleague training in-destination, that better integrates with the new SGS contracted service.

1.4 The Thomas Cook Group should provide industry leadership with ABTA and others to develop the role of the FTO Health & Safety Committee. They should explore whether the common use by major players of external contractors, such as SGS, provides an opportunity for a much more comprehensive and independent collation of industry safety data.

1.5 A complete review of audit reports and templates currently in use is required. They need to reflect the changing legal and contractual backdrop, developing knowledge on risks and the skills and training requirements of the colleagues that will be required to complete them.

1.6 The process for capturing issues requiring action and ensuring follow up requires review. Specifically it is not integrated to the contracting process and it is not clear that enforcement action follows if third parties do not act as required.
1.7 The Thomas Cook Group as part of its bi-annual review of the SGS contract should explore with SGS how existing customer feedback could better be used to direct afety auditing and what requirements SGS might have of any future management information systems.

1.8 The Thomas Cook Group should review its printed and online brochure content with a view to:

1.8.1 making it clear to customers what level of auditing has been undertaken on each type of hotel and package

1.8.2 providing useful advice on what risks might be common both generally whilst on holiday (e.g. pool safety) and those specific to particular destinations (e.g.


1.8.3 providing helpful guidance on the different legal framework that exists by destination (e.g. driving laws, alcohol legislation etc) The objective underlying this is to help customers feel better informed about the destination, resort and hotel choice they are about to make.

1.9 As noted elsewhere the Thomas Cook Group should create a confidential health & safety whistleblowing line for use by both colleagues and suppliers.

Section 2: Carbon Monoxide

2.1 Recommendations 3, 7, 8, 9, 10 of the report issued by the West Yorkshire coroner relate to or touch on the issue of carbon monoxide. I recommend that Thomas Cook Group support these recommendations to the fullest extent possible, taking the lead for the industry where necessary.

2.2 I recommend that within their website and in all brochures Thomas Cook Group include a section on carbon monoxide risks and safety (most likely together with fire risk and safety). Putting the risk in context, outlining symptoms that might point to carbon monoxide poisoning and simple actions on what to do if you suspect such poisoning.

2.3 I recommend that all Thomas Cook Group health and safety training for destination/in-resort personnel include a full briefing on 2.2 above.
2.4 I recommend that Thomas Cook Group source an affordable and portable carbon monoxide monitor and make it available to purchase by travellers via their website using a simple click-through in the order confirmation process or from the ‘health advice / travel check list’ drop box.

2.5 I commend the establishment of the ‘Safer Tourism Foundation’ and encourage Thomas Cook Group in addition to the £1 million funding to commit necessary executive support in pursuit of the objectives of this charity.

2.6 In Corfu, it seems clear that although several checks by operators including Thomas Cook Group had failed to spot the (faulty) boiler its presence had been identified.

This further strongly makes the case for improving the collating of industry data on health and safety issues. Thomas Cook Group should take a leading role on this with the support and facilitation of ABTA as appropriate (see also recommendation 1.8). This is an issue where collaboration rather than competition is appropriate.

Section 3: Quality Assurance and Contracting

3.1 The Thomas Cook Group should prioritise system development to ensure that Group Quality Assurance and the Quality Assurance Managers have available ‘soft’ customer data to help prioritise their workload.

3.2 The process for the removal of a hotel, or other service provider, from the system should be clarified. In particular, levels of service failure and complaints should be objectively set. Where providers fail to meet these the presumption should be removal unless specific and contracted remedial action is agreed.

3.3 The reporting line of Quality Assurance Managers creates the potential for a conflict of interest. Whilst it maximises local and focussed knowledge, checks need to be put in place to ensure their independence is preserved.

3.4 Third party agents should be brought fully within the ambit of the contracting and quality assurance processes.

3.5 Clear binary hurdles should be set before any new hotel or service provider enters the system. Whilst it is appreciated that it will sometimes be necessary to contract and begin to market, before quality and health and safety can be audited (as in a new build hotel for example) the use of a clear ‘stage and gate’ process should be introduced. The burden must shift to commercial and the service provider to prove compliance to be able to proceed.

3.6 The future changes expected to the Passenger Travel Directive will significantly widen the scope of the Group Quality Assurance team. In preparation for this the business needs to develop clear proposals for how this will be achieved, given the market scarcity of well-trained resource in this area.

Section 4: Destination Management

4.1 Many of the above issues have already been identified by the company and have been examined by internal audit in the past 6 months. I believe this audit to be

comprehensive, accurate and its recommendations both sensible and necessary. I urge the Thomas Cook Group to implement its findings in full.

4.2 The incentive structure for in-resort personnel needs to be altered radically with a significant switch towards customer satisfaction levels based on the Thomas Cook Group’s Scandinavian model.

4.3 A full review of all change/lean projects currently in roll-out should be undertaken over the off season months to ensure that learnings from 2015 are incorporated before further roll outs in the 2016 season.

4.4 A full audit of IT infrastructure in-destination should be undertaken and reviewed against the capability requirements of new systems supporting Health & Safety and customer initiatives. A detailed development plan to rectify shortcomings must be created.

4.5 A complete review of all in-destination paperwork to ensure it accords with new processes should be undertaken. A simple – though perhaps costly – solution would be the disposal of all old paperwork and replace with new. Much of the old paperwork is neither ‘on brand’ nor fit for purpose.
4.6 The Thomas Cook Group should review the Rep transfer process and seek new ways, within the current legal structure, to create greater stability in-market. Where appropriate this should include more local recruitment to ensure a greater level of local knowledge and language skills.

4.7 The Thomas Cook Group should create a new internal whistleblowing line for indestination colleagues. The particular focus of this should be their ability to report

for investigation – anonymously if they wish – issues that they have become aware of relating to Health & Safety, Quality Assurance and customer experience.

NB: The Thomas Cook Group does have an internal whistleblowing line. This needs a relaunch to encompass the several recommendations on whistleblowing included in this report.

Section 5: Customer Service & Relations

5.1 Aware of these issues the company has recently audited the progress on the implementation of the new customer charter. This audit identifies clear shortcomings and recommends a comprehensive package of changes. The business needs to move swiftly to debate, agree and implement these proposals.

5.2 With the impending change in the law the Thomas Cook Group has a unique opportunity to better communicate its customer service offer. It is not the same between Concept Resorts, dynamic packages and bed bookings. Physical and online brochures, together with the booking process need to be altered to communicate this clearly.

5.3 The legal backdrop is also an industry-wide issue and I recommend the Thomas Cook Group work with ABTA, other operators and consumer groups to see what collective communication could be achieved to help customers with impending change.

5.4 The Thomas Cook Group needs to create a formal process for destination and customer service colleagues to challenge the accuracy of brochure entries, in particular when they identify the brochure entry does not reflect the contracted service level.

5.5 As noted under ‘Destination Management’ a whistleblowing line for customer facing colleagues to raise, anonymously if they wish, failures to deliver against the customer charter should be established.

5.6 A customer satisfaction KPI should be established and agreed upon and form part of the remuneration and performance review process for all colleagues building on the recent change for senior management.

5.7 The roll out of MATSOFT should be fully evaluated and subject to a full internal audit over the off-season. Particular focus should be placed on ease of use and the completeness of complaint capture in-resort.
5.8 The Thomas Cook Group should significantly increase the empowerment of front line colleagues (destination and customer service) to resolve complaints at first contact.

This will require the ability to offer both cash and vouchers and in destination to require service providers to support. This will require the review of service contracts. ‘First contact’ solved should become a performance measure for complaint resolution.

5.9 The entire suite of written and electronic customer communication should be reviewed to remove, where at all possible, ‘legal’ references, making them more personal, understanding and engaging.

5.10 The reviews identified above must include the creation of a clear pathway towards integrated management information on customer feedback. This is a key stepping stone to using customer feedback to enhance health & safety, as noted elsewhere.

5.11 The Scandinavian customer feedback system and management information should be reviewed to identify if it presents a speedy and affordable solution to a number of these challenges.

5.12 The company should create a culture of celebration of colleagues who go the extra mile to create a great customer experience, especially when this is addressing something that has gone wrong!

Section 6: Crisis and Incident Management

6.1 The Thomas Cook Group must regularly review the implementation of training in its crisis management process. This should be the subject of occasional audit and be part of the line management discussion in the annual performance review process.

6.2 The Thomas Cook Group should introduce a formal, post incident review process for all ‘Gold’ incidents. Where these identify shortcomings in the process or actions that do not reflect those trained, a remedial action plan should be created and completed.

6.3 Regular reviews/simulations should be staged. In particular to test whether appropriate communication takes place in the early stages of an emerging incident.

6.4 Contact lists with ownership of key actions need to be regularly reviewed with multiple deputies established for circumstances such as sickness, holidays or simply difficulty in contacting.

6.5 The Risk Dashboard should be reviewed with a view to shifting the emphasis to consumer outcomes driving actions, rather than financial or reputational consequence.

6.6 The Thomas Cook Group should work together with other key industry players and bodies, such as ABTA, to establish better protocols in the event of a major crisis. In particular with a view to avoiding situations where the Foreign Office advice clashes with the actions being taken by individual companies.
6.7 The Thomas Cook Group should work together with other key industry players and bodies, such as ABTA, to create a clearer process and ownership for the notification

of death to next of kin. This will require engagement with state agencies as well. It is clear that at present a significant potential exists for unnecessary delay and confusion.

6.8 The Thomas Cook Group should review its internal approach towards the costs associated with dealing with crisis. In particular the removal of silos and ‘budget protection’ and a recognition that it’s a company cost to deliver a satisfying outcome for customers.

6.9 Once developed, the ‘bereavement help pack’ must be widely circulated and the necessary training to support the process delivered.