MODERN SLAVERY & HUMAN TRAFFICKING STATEMENT 2019

This is the modern slavery and human trafficking statement of Brookhouse as well as our wholly owned subsidiaries and those joint ventures managed by us. This statement is made pursuant to Section 54, part 6 of the Modern Slavery Act 2015 (the ‘Act’) and applies to all our wholly owned subsidiaries and those joint ventures managed by us as their respective slavery and human trafficking statement for the financial year ending 24 September 2018.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

 

ORGANISATIONAL STRUCTURE

Brookhouse has an extensive property portfolio that covers more than 1.7 million sq. ft. of space and spans across residential, retail and commercial sectors. With origins dating back to the 1930s, Brookhouse Group has developed an extensive network of retail partners, creating a portfolio of which 750,000 sq. ft. is food retail space.

As a group we operate  though wholly owned subsidiaries and joint ventures. In the majority of these arrangements we provide asset management, property development and corporate services. Brookhouse managed joint ventures operate in line with our policies.

Our real estate portfolio is located entirely in the UK. We believe that our own employees are at low risk of modern slavery and human trafficking as the workforce consists primarily of office-based professional skilled labour. We consider our most significant risk areas to be in our supply chain.

 

OUR SUPPLY CHAINS

Our supply chains relate to our property development and investment business and encompass personnel, goods and services to support our property business. We source a wide range of goods and services, and our suppliers cover an extensive range of manufacturers, construction companies, material suppliers and professional service providers. The vast majority of our suppliers are based in the United Kingdom.

 

POLICY

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free, we will ensure background checks at recruitment stage for internal employment and review all commercial appointments through our contractor assurance processes to ensure our supply chain are fulfilling their responsibilities.

We will undertake all practical steps to ensure that our standards are being implemented throughout our own business dealings and those of our supply chains, whilst ensuring that all relevant legislation and regulations are complied with. We will only employ and trade with those who comply with this Policy.

Our Modern Slavery and Human Trafficking Policy demonstrates 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 MODERN SLAVERY AND HUMAN TRAFFICKING

During the next 12 months we intend to build on the procedures from the previous year and continue to review our supplier due diligence processes in relation to slavery and human trafficking.  We will review our procurement processes in order to ensure that all of our existing and new suppliers are asked to confirm that they comply with the requirements of the Act. This will ensure that all organisations working with or on behalf of Brookhouse Group comply with Modern Slavery and Human Trafficking legislation.

 

TRAINING

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, employee awareness training on slavery and human trafficking is provided to Brookhouse Group employees, emphasising the potential risks and the requirements of our staff and our supply chain to operate in accordance with our Modern Slavery and Human Trafficking Policy and in compliance with the Anti-Slavery Laws noted within the Act.

As part of their induction, all new employees will be made aware of the Brookhouse Modern Slavery and Human Trafficking Policy.

This statement has been considered and approved by the Brookhouse Board of Directors on 18th March 2019.

  

Andrew Gardner
Board Director and 
Finance Director
March 2019