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

28 March 2022

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”).

This is our fourth annual modern slavery and human trafficking statement. 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 owns and manages commercial, residential and industrial and logistic 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 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 accountable Committees including Risk, and Health and Safety. FPUK operates within a set of internally developed policies and procedures approved by the FPUK Management Team and communicated to all employees. These policies include but are not limited to:

– Anti-bribery Policy

– Whistle Blowing Policy

– Procurement Policy and Procedures

– Responsible Sourcing Policy

– Grievance and Disciplinary Policy

– Diversity and Inclusion Policy

– Health, Safety and Welfare Policies

– Corporate Social Responsibility Policy

– Enterprise-Wide Risk Management Policy

Our Employee Handbook also contains policies and procedures such as flexible working, compensation and benefits, leave, learning and development, talent and performance management and wellness benefits.

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.

In 2021, we launched a Responsible Sourcing Policy, which specifically details our commitment to responsible sourcing and expectations of our suppliers in this regard. This policy outlines how we expect supplier to align to our expectations in the following four key areas: Environmental Management; Human Rights and Labour Management; Health, Safety and Wellbeing; and Business Ethics and Integrity. We have organised a cross-functional working group who are responsible for implementing the policy requirements across our supply chain and collaborating with our partners to do so. Our commitment to further engaging our supply chain is noted in our Net Zero Carbon Roadmap, published in June 2021.

Due Diligence and Risk Assessment

Direct Employees

All of FPUK’s direct employees are paid at least the London living wage. We have a robust and inclusive recruitment and onboarding procedure in addition to our people strategy.

Property Management

We procure the services of one external property management organisation. The organisation has published their own modern slavery statement and have relevant policies in place. 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 developments and asset enhancement initiatives over £1 million, 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 asset enhancement initiatives, 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.

Suppliers

For our suppliers, we endeavour to use reputable suppliers that demonstrate a commitment to ethical working practices.

Training

All employees and new joiners receive training on our policies as detailed in our Employee Handbook. As the Employee Handbook is updated, staff are informed to ensure they understand the new policies. In early 2021, we developed mandatory sustainability training for all employees, which includes training on ethical working practices. FPUK will look to take a risk-based approach to the roll out of specific modern slavery awareness training. It is planned for all employees or employees in relevant roles to undertake 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) Limited