MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT FRASERS PROPERTY (UK) LTD

15 May 2020

The following statement is made on behalf of Frasers Property (UK) Ltd (“FPUK”) and its subsidiaries in accordance with section 54 (1) of the Modern Slavery Act 2015 (“MSA”).

FPUK is vehement in its opposition to all forms of human trafficking and slavery and will take the necessary steps to ensure ethical practices operate throughout its entire business and supply chain. These same high standards are expected from all of our contractors, suppliers and other business partners.

About Frasers Property (UK) Limited

Frasers Property UK is a Business Unit within Frasers Property Limited, a Singapore-based multi-national Group that owns, develops and manages a diverse and integrated property portfolio. FPUK has a focus on the development of residential and commercial properties and owns and manages commercial and residential assets across the United Kingdom.

The FPUK financial year ends on September 30th.

Organisational Structure and Supply Chains

FPUK currently has less than 100 employees and has staff and assets based in Scotland and England. FPUK headquarters are located in London, UK.

FPUK procures services and products from a range of sectors including property management, construction, project management, contractors, professional service providers, and corporate goods and services.

Organisational Policies

FPUK’s processes for identifying and managing risk, including any risks around modern slavery and human trafficking, are set by the Board and delegated to the Finance and Risk Committee. FPUK operates within a set of internally developed corporate policies and procedures approved by the Board of Directors and communicated to all employees. These policies include but are not limited to:

– Anti-bribery Policy

– Whistle Blowing Policy

– Procurement Procedure

– Tender Policy

– Code of Business Conduct

– Corporate Social Responsibility Policy

– Enterprise Wide Risk Management Policy

– Health and Safety Policy

– Human Resources Policy Suite contains policies and procedures such as flexible work, compensation and benefits, leave, learning and development, talent and performance management and health and safety.

Frasers Property UK recognises that modern slavery is a serious issue and consequently FPUK’s suppliers are expected to comply with the MSA and, where necessary, to require compliance through their own supply chain.

Due Diligence and Risk Assessment

Direct Employees

All direct employees are paid at least the London living wage. It is our target to earn the Living Wage Foundation Accreditation in the near future. We have a robust recruitment and on boarding procedure in addition to a wellbeing strategy. For our suppliers, we endeavour to use reputable suppliers that demonstrate a commitment to ethical working practices.

Organisational Structure and Supply Chains

Property Management

We procure the services of two external property management organisations. Both organisations have published their own modern slavery statements and policies. Some ways in which the policies are put into practice are through modern slavery awareness training, sharing best practices with suppliers, devising action plans for high risk areas and suppliers, hosting supplier events and site audits. We are looking into effective ways to audit some of these practices on our sites so that their commitments are consistently upheld.

Construction

For all new large developments and major refurbishments, we require the principal contractor to register with the Considerate Constructors Scheme (CCS). The CCS is a voluntary, not for profit scheme that encourages contractors to meet best practice standards in areas such as workforce, safety, community and environment. The CCS Code of Practice requires registered contractors to provide a workforce environment where everyone is respected, treated fairly and the staff meet high standards of welfare, health and safety. The Code of Practice is monitored through audits.

In the construction of new buildings and major refurbishments, we seek building certifications such as BREEAM. Rating tools such as BREEAM include a ‘Materials’ section which promotes lessening the environmental impact of materials and procuring materials in a responsible way.

Training

All employees and new joiners receive training on all of our policies as detailed in our Employee Handbook. As the employee handbook is updated, staff are informed to ensure they understand the new policies. FPUK will look to take a risk-based approach to the roll out of modern slavery awareness training. It is planned for all employees or employees in relevant roles to undertake specific modern slavery training to understand the risks in our supply chains.

The Frasers Property UK Management Team and Board are committed to ethical business practices and supporting policies and procedures to eradicate modern slavery any modern slavery found in our supply chain.

Ilaria del Beato
Chief Executive Officer
Frasers Property (UK) Ltd