Statement of Peel Holdings Land and Property (UK) Limited on behalf of Peel Land & Property pursuant to the Modern Slavery Act 2015 ("The Act")
This is the modern slavery and human trafficking statement of Peel Holdings Land and Property (UK) Limited (Peel Land & Property) and all its subsidiaries and UK Group companies. This statement is made pursuant to Section 54, part 6 of the Modern Slavery Act 2015 (the ‘Act’) and has been adopted by all subsidiaries as their respective slavery and human trafficking statement for the financial year ending 31 March 2018.
The principal activities of Peel L&P include property investment, development and trading. Peel L&P lies at the heart of The Peel Group, one of the foremost real estate, infrastructure and transport investment enterprises in the UK. The Peel L&P Group own and manage 1.2 million m² of property and 15,000 hectares of land and water. Our holdings are concentrated in North West England but we also own and manage significant assets in the Clyde, Yorkshire and the Medway in Kent, with a total portfolio value of £2.5 billion.
Due to the diverse nature of the business, our supply chain comes from many different areas. However, in all its dealings with its suppliers Peel strives to ensure that the highest ethical standards are reached at all times.
Peel is committed to ensuring, as far as practically possible, that there is no modern slavery or human trafficking in our supply chains or in any part of our business. There are various policies in place in relation to staff conduct and welfare that continue to be reviewed and, where necessary, amended so that they appropriately highlight the Group’s stance and protocol regarding forced labour, slavery or human trafficking to staff and third parties. In addition, a separate Human Trafficking and Modern Slavery Policy has been issued to all employees and will be included in the induction process.
All of our new starters are required to read, and acknowledge that they have done so, each of the policies referred to above.
The following policies are considered to be of particular importance in tackling modern slavery and human trafficking:
· Code of Professional Conduct Policy which provides a set of rules to ensure that all employees uphold the highest level of ethical conduct in their day-to-day business;
· Dignity at Work Policy which aims to ensure that all staff are treated and treat others with dignity and respect, free from harassment or bullying;
· Equal Opportunities Policy which aims to create a working environment in which all individuals are able to make best use of their skills, free from discrimination or harassment;
· Whistleblowing Policy which encourages the reporting and exposure of unethical behaviour. All matters raised via whistleblowing or through the auditing processes are diligently investigated and appropriate action taken.
· Supplier Charter which sets out our aim to engage with all of our key suppliers.
During the past 12 months we have updated our general conditions of contract to make it a requirement that all suppliers must confirm that they comply with the Modern Slavery Act. In addition, as part of our new supplier process we ensure that any new supplier has confirmed that they comply with the Act before they are accepted as a new supplier. We will continue to review our supplier due diligence processes, our Procurement Policy and Supplier Charter in relation to slavery and human trafficking over the forthcoming year.
We have recruitment systems in place to prevent forced labour and to ensure that all employees are entitled to work in the UK. We ensure that all staff directly employed by Peel do so at their own free-will and understand that they can cease their employment at any time under the terms of their employment contract. We compensate all staff directly employed by Peel with wages and benefit packages that meet or exceed statutory minimum requirements. We abide by the Working Time Directive, unless staff directly employed by Peel voluntarily chooses to opt-out (within the limitations imposed by the Working Time Directive).
Risk Management and Effectiveness
Peel has an Internal Audit function that reviews various systems and processes to provide an independent assurance that our risk management governance and internal control processes are operating effectively in accordance with the Codes of Professional Conduct and Ethics and International Standards governed by the Charted Institute of Internal Audit (CIIA).
As the vast majority of our suppliers are based in the United Kingdom we consider that they pose minimum risk in terms of non-compliance with the Act. Although we see our business as low risk in relation to the threat of slavery and human trafficking offences being committed, we intend to carry out compliance audits on a regular basis.
Our Human Resources department have carried out a review of our employee development programme. It was decided that apart from our externally sourced training modules we would roll out a new on-line training solution. This has now been rolled out successfully across the business and we will be offering annual training to all employees specifically in respect of Modern Slavery.
During the year we have also fully embedded our Ambition training programme across the Group for all managers and this clearly sets out the standards expected of our managers in the treatment of employees, including contractors and suppliers.
This statement has been considered and approved by the Company’s Board of Directors.