Modern Slavery and Human Trafficking Statement
The Modern Slavery Act 2015 (the “MSA”), requires companies, which carry on 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 ensuring, as far as possible, that our own business and our supply chain are aware of and addresses these issues.
Shaftesbury respects international principles of human rights and has been a signatory of the UN Global Compact since 2015. This is our second annual slavery and human trafficking statement and sets out the activities we have undertaken to take to prevent, as far as practical, modern slavery and human trafficking in our business and supply chain during the year ended 30 September 2017.
Shaftesbury is a FTSE 250 listed company which operates solely in the UK, investing in real estate in London’s West End,. At 30 September 2017, our portfolio valuation was £3.64 billion and comprised nearly 600 buildings across 14 ½ acres and a mix of uses.
Whilst we have a small team of 30 employees, Shaftesbury has an extensive external supply chain. We see our main risks within the scope of this legislation as relating to the procurement of materials and labour services connected with building refurbishment projects and property management. We contract with a number of suppliers in these activities.
We are dedicated to ensuring that our employees and out-sourced providers are aware of the legislation and are actively working together to tackle modern slavery and human trafficking risks.
OUR POLICIES AND TRAINING
We have policies in place within our business which set out our approach to these issues and are outlined in our employee handbook and Sustainability Policy which is available on our website. They are summarised below.
Within our own office and across the buildings we own, we support the ten principles of the UN Global Compact on human rights, labour, environment and anti-corruption. 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 employees 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.
The policy also covers 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.
Following our initial training session with employees and first tier suppliers we have provided ongoing guidance through our annual sustainability training and awareness session.
All our employees receive compliance training which includes specific reference to slavery and human trafficking, and in particular the risks our supply chain is faced with.
WITHIN OUR SUPPLY CHAIN
Our supply chain is extensive as we have many outsourced service providers working on our behalf including direct suppliers such as legal advisors and property managers as well as indirect suppliers which includes for example cleaning, security and suppliers of materials and labour in refurbishment projects. All of the policies, referred to above, 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.
We have identified the higher risk areas within our supply chain and are working to raise awareness and monitoring processes. We have developed a Supplier Code of Conduct, which has been circulated to our principal suppliers for inclusion in contracts throughout our supply chain and available on our website.
Advisers, property managers, project managers and contractors must adhere to the labour standards required by us which include requiring the implementation of payment of the London living wage, as a minimum for London based employees, and ensuring that all suppliers and contractors never use forced, compulsory or child labour.
Advisers, project managers and contractors are also required to have regard to current UK environmental and health and safety legislation. They are required to provide comfortable working conditions for employees involved in the refurbishment projects and use construction materials reputably sourced with recognised certification for the projects All refurbishment contractors are required to register with the Considerate Constructors Scheme (CCS) a non-profit making organisation designed to encourage best practice in areas including, environmental, safety, community and workforce welfare. By registering with the CCS the contractors commit to providing a workplace where everyone is respected and treated fairly and are subject to third part audit to verify that this is the case. During 2017, all our sites exceeded the minimum compliance requirements of 25 out of 50 with an average score of 34.8.
During 2018, we will continue to address the risks identified above and seek opportunities to further reduce the risk of human trafficking and modern slavery throughout our business operations and supply chain. As part of this commitment we will do the following:
- We will seek accreditation with the Living Wage Foundation.
- We will monitor the implementation of our Supplier Code of Conduct and ensure its inclusion in all future contracts within the supply chain.
- We will undertake a further awareness campaign targeted at our refurbishment sites through the use of leaflets and posters and use of modern slavery online courses
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 2017 and will be reviewed and updated to outline our progress, achievements and new targets for the year ending 30 September 2018.
31 March 2018