Modern Slavery Act

MODERN SLAVERY POLICY STATEMENT

Introduction

This statement sets out Purelake New Homes Ltd.’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year [1 April 2024 to 31 March 2025}.

As part of the construction industry the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Purelake New Homes Ltd.

The Company operates in the new build residential development sector and constructs projects ranging from small housing schemes to major multi block apartment developments.

All professional and administration staff are directly employed by the Company.

All groundworks foremen and operatives are directly employed by the Company.

All trades other than groundworks are provided by bona fide subcontractors.

The Company does not use labour procured from temporary employment agencies.

The Company uses a wide range of suppliers, all based in the UK.

The organisation currently operates in the following geographical areas:

  • South London Boroughs
  • North Kent

The following is the process by which the company assesses whether particular activities are high risk in relation to slavery or human trafficking:

Assess the qualification level for the labour required. Skilled workers are much less liable to be affected by unscrupulous employment practices such as “gang master” employment.

Assess the subcontract company being offered the trade contract by discussion at pre contract meetings, followed up by checks such as employee payment / tax / NIC details.

Avoid using any agency labour on a “hired in” basis.

Suppliers to be examined regarding origin of materials supplied and whether they have been produced in areas / countries known to utilise suspect employment practices. Assurances to be obtained where appropriate.

High-risk activities

The following activities are considered to be at high risk of slavery or human trafficking:

Generally, in the construction industry these are unskilled labourer roles drawn from some “employment agencies” or gang masters. Will be avoided by not using such organisations.

Responsibility

Responsibility for the organisation’s anti-slavery initiatives is as follows:

  • Policies: Drawn up by the Company’s HR Manager in conjunction with the Board of Directors.
  • Risk assessments: Each project will be examined at pre -construction stage to establish any area of risk pertinent to that particular development.
  • Investigations/due diligence: Before the employment or award of trade contract sub-contractors and suppliers to be examined on their labour practices.
  • Training: HR staff and senior managers will receive training to identify areas which are known to be exploited by unscrupulous organisations.

Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  1. Whistleblowing policy: The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can address these to HR Manager or line managers.
  2. Employee code of conduct: The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
  3. Supplier/Procurement code of conduct: The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship. [Describe the process and steps taken to implement the code of conduct in relation to slavery and human trafficking, including examples (not necessarily named) where action has been taken to address specific slavery and human trafficking risks.]
  4. Agency workers policy: The Company refuses to use agency workers due to the risks involved.

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

  • Mapping the supply chain broadly to assess product or geographical risks of modern slavery and human trafficking.
  • Evaluating the modern slavery and human trafficking risks of each new supplier [this may be part of a more general human rights or labour rights assessment].
  • Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping.
  • Conducting supplier audits or assessments through [the organisation’s own staff/third party auditor], which have a greater degree of focus on slavery and human trafficking where general risks are identified.
  • Creating an annual risk profile for each supplier.
  • Taking steps to improve substandard suppliers’ practices, including providing advice to suppliers through [third party auditor] and requiring them to implement action plans [provide examples].
  • Participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular [provide examples such as participation in “Stronger together” or “Ethical trading” initiatives].
  • Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship [provide examples].

Performance indicators

The organisation has reviewed its key performance indicators (KPIs) considering the introduction of the Modern Slavery Act 2015. As a result, the organisation is:

  • Requiring all staff/supply chain managers/HR professionals to have annual refresher training on modern slavery.
  • Review and improve our system for supply chain verification annually, whereby the organisation evaluates potential suppliers before they enter the supply chain; and review and improve our existing supply chains annually, whereby the organisation evaluates all existing suppliers.

Training

The organisation requires all staff/supply chain managers/HR professionals within the organisation to complete training on modern slavery as a module within the organisation’s wider training programme.

The organisation’s modern slavery training covers:

  • Our business’s purchasing practices, which influence supply chain conditions, and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline.
  • How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available.
  • How to identify the signs of slavery and human trafficking.
  • What initial steps should be taken if slavery or human trafficking is suspected.
  • How to escalate potential slavery or human trafficking issues to the relevant parties within the organisation.
  • What external help is available, for example through the Modern Slavery Helpline, Gangmasters Licensing Authority and “Stronger together” initiative.
  • What messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies.
  • What steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply chains.

Awareness-raising programme

As well as training staff, the organisation has raised awareness of modern slavery issues by distributing flyers to staff/putting up posters across the organisation’s premises/circulating a series of emails to staff.

The flyers/posters/emails] explain to staff:

  • The basic principles of the Modern Slavery Act 2015.
  • How employers can identify and prevent slavery and human trafficking.
  • What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation.
  • What external help is available, for example through the Modern Slavery Helpline.

The statement of policy must be brought to the attention of all employees and is readily available to all interested parties. It will be reviewed at least annually and revised if necessary. Any such revisions will be brought to the attention of all employees.

Signed by

Barry White – Managing Director

Date: 17/06/2024

Law relating to this document

Leading statutory authority

Modern Slavery Act 2015
Transparency in supply chains etc: a practical guide
Stronger together initiative
Ethical trading initiative
Gangmasters Licensing Authority
Global slavery index
Business and human rights resource centre
International Labour Organisation: forced labour, human trafficking and slavery
Guiding principles on business and human rights: implementing the United Nations “protect, respect and remedy” framework

Section 54 of the Modern Slavery Act 2015 requires commercial organisations to prepare a slavery and human trafficking statement for each financial year of the organisation. The statement must set out the steps that the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business. If the organisation has not taken any such steps, it must still publish a statement to that effect.

Although s.54 of the Modern Slavery Act 2015 was brought into force on 29 October 2015, the requirement to prepare a slavery and human trafficking statement applies only to financial years ending on or after 31 March 2016. This means that an organisation with a financial year running from 1 April to 31 March must publish a statement for its 2015/16 financial year.

Section 54 states that the organisation’s statement may include information on:

  • the organisation’s structure, business and supply chains (covered in Organisational structure and supply chains in this model statement);
  • its policies in relation to slavery and human trafficking (covered in Relevant policies);
  • its due diligence processes in relation to slavery and human trafficking in its business and supply chains (covered in Due diligence);
  • the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps that it has taken to assess and manage that risk (covered in Organisational structure and supply chains);
  • its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate (covered in Performance indicators); and
  • the training about slavery and human trafficking available to its staff (covered in Training).

These headings are recommendations only and organisations may choose to set out their statement differently.

The duty applies to commercial organisations with a total turnover of at least £36 million per year. “Commercial organisations” that are covered by the duty are body corporates and partnerships that carry on a business, or part of a business, in the UK, supplying goods or services. See FAQs > Which employers are required to publish a slavery and human trafficking statement? for more details.

The slavery and human trafficking statement must be approved at the highest level of an organisation, for example by the board of directors, and signed by a director if the organisation is a body corporate or approved by the members and signed by a designated member if the organisation is a limited liability partnership.

The organisation must publish the slavery and human trafficking statement on its website and include a link to the statement in a prominent place on the homepage. If it does not have a website, it must provide a copy of the slavery and human trafficking statement within 30 days of any written request for one.

Notes

HR departments are unlikely to produce their organisation’s modern slavery and human trafficking statement in isolation. Other areas of the business should also be heavily involved in the statement’s preparation, including the legal, ethical trade, risk management, procurement, and facilities management departments.

As modern slavery and human trafficking statements must be available to the public, they should be written in simple language that is easily understood. Organisations should avoid including jargon that is sector-specific or used only within the organisation.

A modern slavery and human trafficking statement does not have to set out the text of every document to which it refers. It is sufficient for the statement to provide links to supporting documentation, such as policies.

Organisations should build on their modern slavery and human trafficking statements each year and statements should evolve and improve over time.