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 third 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 2018.
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 2018, our portfolio valuation was £3.95 billion and comprised nearly 600 buildings across 15 acres and a mix of uses.
Whilst we have a small team of 31 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.
Our Sustainability Policy is reviewed and approved by the Shaftesbury Board and it includes policies which are summarised below.
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 to present a risk of modern slavery or human trafficking.
Employees, contractors or suppliers who become aware of possible improper, unethical or illegal behaviour are encouraged to report any concerns, through using the Whistleblower's Helpline operated by ExpoLink:
Telephone: 0800 374 199
App: SpeakingUp (available through the Apple App Store and Google Play for Android). Access Code: Shaftesbury
Anti-bullying and harassment policy
We operate a strict policy against unwanted conduct which would affect 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.
Regular training is undertaken with employees and first tier suppliers and 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 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, This is provided annually to each key business within our supply chain, to encourage them to adopt and enforce similar policies in their own business.
Based on our annual risk assessment, we believe the busiess overall has a low risk of modern slavery in both our own operations and in our immediate supply chain. However, we are pro-active in ensuring we are making our workforce, contractors and suppliers aware of areas of potential risk and we are working to raise awareness and monitoring processes.
In 2017 we developed a Supplier Code of Conduct , which was reviewed and updated in 2018. This document has been circulated to our principal suppliers for inclusion in contracts throughout our supply chain and is available on our website.
This includes our whistleblowing helpline details which is available for use by our suppliers.
All new suppliers are now required to acknowledge that they will conform with our Supplier Code of Conduct. Through our tendering and contracting procedures, suppliers are required to uphold the requirements of the Supplier Code of Conduct and ensure any subcontractors they appoint do the same. These obligations are reflected in our contractual documentation.
All advisers and contractors must adhere to the labour standards we require 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. In support of this, during 2018 we became accredited "Living Wage Employers" by the Living Wage Foundation.
Advisers 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 party audit to verify that this is the case. During 2018, all our sites exceeded the minimum compliance requirements of 25 out of 50 with an average score of 35.6.
We raised awareness on our refurbishment project sites through use of Stronger2gether posters and updates within our annual sustainabiliity workshop attended by our project managers and managing agents. This year, principal contractors that work on our portfolio, attended a sustainability forum that included raising awareness of modern slavery and human trafficking.
During 2019, 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:
- Maintain our accreditation with the Living Wage Foundation.
- Continue to monitor the implementation of our Supplier Code of Conduct and ensure its inclusion in all contracts within the supply chain.
- Continue to ensure that all our employees are trained on the Act, highlighting key signs and indicators that someone may be a victim of modern slavery.
This statement is in compliance with section 54 of the MSA and relates to Shaftesbury PLC and all its subsidiaries. It is made in respect of its financial year ended 30 September 2018 and will be reviewed and updated to outline our progress, achievements and new targets for the year ending 30 September 2019.
Approved by the Board on 7 February 2019.