We are committed to continually improving our practices to ensure no slavery and human trafficking are enabled within the company or taking place within its supply chains. We consider the nature of our business to constitute a low risk from a Slavery and Human Trafficking perspective as we have no business presence whatsoever overseas and tightly control all employment practices within the Company and our subsidiaries.
We are Estate and Lettings agents in the property sector. Our Regulators are the RICS. Our and our subsidiary companies’ business comprises circ. 75 offices of estate and letting agencies across Greater London and a few support offices. We have over 1,200 employees and operate in the UK alone. We and our subsidiaries have a combined annual turnover of circ. £70M.
OUR SUPPLY CHAINS
Our supply chains include:
1. Office cleaning suppliers
2. IT hardware suppliers
3. IT software suppliers
4. Office equipment suppliers
5. Office furnishings suppliers
6. Property Management contractors
7. Office fit-out contractors and building works contractors
8. Professional Services suppliers
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business or in our supply chains. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk of slavery and human trafficking in our supply chains, we have been looking at our existing and new suppliers of goods and services as detailed above to determine where and how we could ensure there is no slavery and human trafficking affecting any of our suppliers.
We concluded that there is very little we could do in respect of suppliers of goods such as suppliers of office furnishings and equipment as these companies sell to us online under their own Terms & Conditions of Business and cannot be engaged to negotiate specific terms for individual organisations or purchasers. However, we only engage with and buy our equipment from reputable organisations with significant and reliable online presence which in our view would help to ensure we do not indirectly encourage modern slavery or human trafficking.
So far as suppliers of services are concerned, specific contracts for such services are much more common and could be more readily negotiated. We have implemented a system whereby we require compliance clauses in each new contract we are entering into with such suppliers to contractually ensure their own business is free of modern slavery and human trafficking and where applicable and practicable, the businesses of their own subsidiaries and suppliers.
Following the above, we continually develop systems to:
• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistle blowers.
IMPLEMENTING OUR VALUES
We have zero tolerance to slavery and human trafficking.
We have a dedicated risk and compliance committee, which consists of representatives from the following departments:
• Human Resources
The committee meets regularly to discuss the progress, improvement and further implementation of our risk and compliance policies and procedures.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and any risk related to our own business, our coaching team provides regular training to all our staff.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 30 September 2017.