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Modern Slavery Statement

Introduction

This statement applies to Stonebond Group Limited (referred to in this statement as ‘the Organisation’) and all subsidiary companies. The information included in the statement refers to the financial year 2020.

Organisational structure

The main activity carried out by the Organisation is that of a premium housebuilding business focused on the development of both private and affordable/ build-to-rent homes within the Home Counties with operations established in Chelmsford, St Albans and Sevenoaks. Such offices are supported by a limited number of central functions e.g. H&S, legal, IT that are centralised at the group level. The Organisation operates only in the UK. The labour supplied to the Organisation in pursuance of its operation is carried out in wholly in the United Kingdom.

Definitions

The Organisation considers that modern slavery encompasses:

• Human trafficking

• Forced work, through mental or physical threat

• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse

• Being dehumanised, treated as a commodity, or being bought or sold as property

• Being physically constrained or to have restriction placed on freedom of movement.

Commitment

The Organisation is not currently required in law to make formal declarations relating to the Modern Slavery Act 2015.

However, the Organisation has a zero-tolerance approach to any form of modern slavery. The Organisation acknowledges its responsibilities in relation to tackling modern slavery and voluntarily commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation is committed to acting ethically and with integrity and transparency in all business dealings and to safeguard against any form of modern slavery taking place within its business or supply chain. With this in mind, the Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom and in many cases exceeds those minimums in relation to its employees.

Supply chains

The Organisation’s supply chain consists of third-party suppliers, contractors and subcontractors on whom the Organisation relies on to execute its development projects. The suppliers vary in size from larger corporations to individual tradesmen. The Organisation has a centralised materials procurement team who control a database of all the Organisation’s suppliers on behalf of each office.

Potential exposure

The Organisation considers its main exposure to the risk of slavery and human trafficking to exist in using suppliers, contractors, and sub – contractors which are smaller businesses and not required in law to comply with the Modern Slavery Act 2015. To alleviate such risk the Organisation’s materials procurement team regularly review their database of suppliers to assess the risk of modern slavery. In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited. It has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

Steps

The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers. The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery. In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place: • a review of its supplier contracts to include termination powers in the event that the supplier is, or is suspected, of being involved in modern slavery • created an action plan to address the risks of modern slavery • communication of this policy to those working with the Organisation to ensure awareness and to embed a zero-tolerance policy towards modern slavery

Next Steps

• To develop further this policy and the action plan

• To implement training for employees as necessary

Key performance indicators

The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.

• Number of reports received from employees, the public or law enforcement agencies to indicate that modern slavery has been identified or associated with the Organisation

• Number of Reports received from within the Organisation’s supply chain to indicate that Modern Slavery has been identified.

The Organisation has, to date, not received any such reports from employees, the public, law enforcement agencies or our supply chain to indicate that modern slavery practices are taking place.

Policies

The Organisation has the following internal policies which further define its stance on modern slavery and require that the Organisation conducts its business in an ethical and transparent manner:

• Anti-Bribery and Corruption Policy

• Whistleblowing Policy

• Recruitment Policy

• Code of Conduct

Slavery Compliance Officer

The Organisation has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations. This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

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