MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT
Modern Slavery Act 2015
This statement is made by Churchill Retirement Living Limited. The Board has approved this statement which is made in accordance with section 54 of the Modern Slavery Act 2015 (the MSA) and covers the financial year from 1st July 2018 to 30th June 2019.
We have a zero-tolerance approach to modern slavery and human trafficking and we are committed to acting ethically, transparently and with high integrity in all our business dealings and relationships. We aim to achieve this commitment by implementing and enforcing effective systems and controls designed to ensure modern slavery is not taking place anywhere within our business, our partners or in any of our supply chains and by adhering to our obligations under the Act.
We are a retirement property developer based solely in the UK. The company has its head office and a regional office in Ringwood, Hampshire and regional offices in Byfleet, Bromsgrove and St Albans. We provide high quality Retirement Apartments for independent living and have over 24 years’ experience in this field as market leader.
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 within our business or that of our partners or supply chains.
Identify and assess potential risk areas in our supply chains.
Monitor and review our regional structures to determine the highest risk types in our supply chain including
• Labour only suppliers (including recruitment, cleaning, bricklayers, carpenters and security)
• Labour and material suppliers (including groundworkers, roof tilers and plasterers).
• Selected suppliers of raw materials which may be sourced from outside the UK.
Engage with our Supply chain identified as a higher risk
Review their own procedures on Modern Slavery and assist where necessary to ensure their policies are aligned and ensure that a zero-tolerance approach is reflected across our supply chain.
Exert Influence on our existing and future supply chain
The New Churchill Retirement suite of Terms and Conditions will include robust anti-modern slavery provisions, including 'flow down' provisions to ensure that the obligations are passed on down the supply chain and not restricted to the first link in the chain. All updated Group and regional agreements will include these terms.
A revised site induction procedure has been introduced as well as a system of site checks on an irregular basis to ensure compliance.
Site wide information posters are being rolled out across the business during the current financial year to make all workers aware of the warning signs of modern slavery and how to report these internally so that they can be investigated. Employees as well as suppliers and subcontractors must be encouraged to raise any concerns or suspicions at the earliest possible stage and without fear of detrimental treatment.
Providing training to all relevant members of staff to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business including provision of directors’ briefings on the subject.
This Statement has been approved by the Board of Churchill Retirement Living Limited and in accordance with the requirements of the MSA it will be reviewed and updated annually.
Chief Financial Officer – Churchill Retirement Living
1st July 2018