Modern Slavery Statement
The Modern Slavery Act 2015 (the “MSA”) which applies after 1 April 2016, requires public and private companies, and partnerships, which carry on business or part of a business in the UK and have a global turnover of over £36 million, to disclose information detailing how they are tackling slavery and human trafficking in their supply chain. Shaftesbury is committed to doing so within our own business and in our supply chain. Shaftesbury is a FTSE 250 listed company operating in the UK, which invests in real estate in London’s West End, a location that has many unique features which bring prosperity, resilience and opportunity to the local economy. Whilst we have a small and strong internal team of 27 employees, Shaftesbury has an extensive external supply chain. We are dedicated to ensuring that our people internally and externally are aware of the new legislation and are actively working together to tackle modern slavery and human trafficking risks.
WITHIN OUR BUSINESS
We have numerous policies in place within our business, which are outlined in our employee handbook and Sustainability Policy.
We support the ten principles of the UN Global Compact on human rights, labour, environment and anti-corruption and our key policy goals include adhering to the Universal Declaration of Human Rights, International Bill of Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work.
Health and Safety policy
We provide and maintain safe and healthy working conditions, regularly monitor the management of our health and safety at work and make regular equipment safety inspections (any health and safety incidents are notified to the Company Secretary immediately).
We encourage all staff to report any serious concerns that they may have with regard to wrongdoing or criminal activity related to any aspect of their work, the conduct of others or the running of our company including activities carried out on behalf of the company, for example by managing agents.
We are going to extend this policy to cover reporting any activity which is perceived as a risk of modern slavery or human trafficking.
Anti-bullying and harassment policy
We operate a strict policy against unwanted conduct that affects the dignity of any employee in the workplace. Offensive, intimidating, malicious or insulting behaviour which, through the abuse or misuse of power, makes the recipient feel vulnerable, upset, humiliated or threatened is unacceptable.
The promising or giving of a financial or other advantage where it induces or rewards a person to perform a function or activity is prohibited by the Bribery Act 2010. Shaftesbury promotes the ethical conduct of business and requires all employees to report any instance where bribes are offered or requested.
We have had an initial training session with employees and first tier suppliers.
We are planning for all our internal staff to receive specific training on slavery and human trafficking, and in particular we will flag the particular risks our supply chain is faced with.
WITHIN OUR SUPPLY CHAIN
Our supply chain is fairly extensive as we have many outsourced service providers working on our behalf. All of the above policies are appended to our Sustainability Policy, which is provided annually to each key business within our supply chain, to encourage them to adopt and enforce similar policies in their own business.
In the first year of reporting in accordance with this legislation, we have mapped out our supply chain and contacted our first tier suppliers, asking them to comply with the MSA and circulate the Government’s poster on site to raise awareness of the new legislation. Where these first tier suppliers are responsible for a second tier, we have asked them to communicate our approach to their supply chain.
We are also working closely with our managing agents to draft a specific clause dealing with modern slavery and human trafficking, to be inserted in all of Shaftesbury’s supplier contracts.
The following two standards are also applicable within our supply chain: :
Requirements for refurbishment projects
Advisers, project managers and contractors are required to have regard to all current UK environmental and health and safety legislation. Furthermore, advisers, project managers and contractors are required to provide comfortable working conditions for employees involved in the refurbishment projects and use reputable sources of construction materials for the projects.
Requirements for management of the portfolio
Advisers, project managers and contractors must adhere to the labour standards required by Shaftesbury which include promoting the implementation of payment of the living wage, but ensuring that all suppliers and contractors comply with the payment of the minimum wage to their employees and never using forced, compulsory or child labour.
This statement is in compliance with section 54 MSA and relates to Shaftesbury PLC and all its subsidiaries. It is made in respect of its financial year ended 30 September 2016 and will be reviewed and updated in 12 months to outline our progress, achievements and new targets.
Approved by the Board on 23 November 2016.