Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Countryside has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within our business or supply chain.
Our business and supply chain
Countryside is a leading UK home builder and urban regeneration partner, operating in and around London and the South East of England, and with a presence in the North West of England and West Midlands through its Partnerships division. Countryside does not operate outside of the UK.
Our supply chain consists of hundreds of third party suppliers, contractors and sub-contractors on whom we rely to execute our projects, through the supply of goods and services. The suppliers vary in size from large corporations to individual tradesmen.
Our high risk areas
Many of Countryside’s suppliers, contractors and sub-contractors are smaller businesses and are not required in law to make formal declarations relating to the Act. Countryside recognises that these suppliers/contractors, along with their suppliers and sub-contractors (including those outside the borders of the United Kingdom) present the most risk to its business in relation to the Act.
We operate a number of internal policies which require that we conduct business in an ethical and transparent manner. These include:
• Anti-slavery policy - which sets out Countryside’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.
• Recruitment policy – which includes the requirement to conduct eligibility checks for the right to work in the UK for all employees to safeguard against human trafficking or individuals being forced to work against their will.
• Anti-Bribery and Corruption policy – which sets strict limits for the giving or receiving of gifts or hospitality and requires transparency for all employees through quarterly disclosure.
• Whistleblowing policy – which facilitates a third party confidential line in cases where an individual discovers information which they believe shows serious malpractice or wrongdoing within the Company (the individual is able to disclose this information without fear of reprisal).
• Code of Conduct - which explains the manner in which all Countryside employees and agents must behave and how we expect our suppliers and contractors to act.
Obligations on our suppliers
Countryside operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all new suppliers before allowing them to become a preferred supplier. Countryside’s Modern Slavery & Human Trafficking policy forms part of our contract with all new suppliers and they are required to confirm that no part of their business operations contradicts this policy. We reserve the contractual right to terminate any supplier contract in the event of breach of this requirement.
Given that many of Countryside’s suppliers are long-standing, we have also written to all such suppliers asking them to make the same confirmations to us that we require from new suppliers.
The confirmations we require from all preferred suppliers are:
1. They have taken steps to eradicate modern slavery within their business;
2. They hold their own suppliers to account over modern slavery;
3. They pay their employees at least the national minimum wage / national living wage (as appropriate); and
4. We may terminate the contract at any time should any instances of modern slavery come to light.
We have conducted training for all of our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain. Refresher training will take place at regular intervals and all new managers with recruitment responsibility receive training in this area. Training is also available to all employees on Countryside’s learning portal.
Our performance indicators
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
• No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
• No reports are received from within our supply chain to indicate that modern slavery practices have been identified.
Further steps to be undertaken
We intend to ask certain suppliers (in exceptional circumstances) to produce an annual slavery and human trafficking report, setting out the steps they have taken to ensure slavery and human trafficking is not taking place in any part of their business or supply chain.
This statement was approved by the Board of Countryside Properties PLC on 25 October 2016.
Signed: (Group Chief Executive) 28th November 2016