Modern Slavery Policy Statement

Introduction

Keepmoat Homes Limited, its subsidiaries and group companies (the “Group”) are committed to maintaining a high ethical standard and operating in a transparent, honest and responsible way.

This policy statement explains the measures the Group takes to ensure that this is achieved and to uphold the laws and regulations relevant to the Modern Slaver Act 2015.

Policy statement

The Group is committed to preventing modern slavery in all its forms, and ensuring that effective processes are implemented and enforced, to eliminate the opportunity for modern slavery to exist within our business or our supply chain.

Our internal Modern Slavery Policy can be accessed here.

Our Business

Keepmoat Homes Limited is a national market leader in residential development and is involved in land acquisition and building new homes and communities across the UK. The Group consists of the following trading companies with revenue in excess of £590m in the 12 months between 1 November 2017 and 31 October 2018:

  • Keepmoat Limited;
  • Keepmoat Homes Limited;
  • MCI Developments Limited

We recognise that every member of staff has a role to play in combatting this crime, by remaining alert to the risk of slavery, however small it may be, within our business and within our supply chain.

Preventing modern slavery

The Group implements a number of measures to prevent modern slavery within our business or our supply chain. As part of this commitment, we continue to strive to:

  • Undertake regular risk assessments to identify vulnerable sectors of our business, and implement appropriate control measures;
  • Conduct due diligence on sub-contractors and suppliers, to ensure that we only utilise sub-contractors and suppliers who are also committed to preventing modern slavery;
  • Ensure our sub-contractor and supplier contracts include provisions which place obligations on parties that we do business with, to comply with the Modern Slavery Act 2015
  • Deliver training and guidance to staff on preventing modern slavery within our business and supply chain;
  • Encourage staff to report concerns and protect reporters of wrong doing, via our whistle blowing policy;
  • Maintain a robust recruitment and checking procedure, to ensure that all employees of Keepmoat are appropriately vetted;
  • Publish and maintain a Modern Slavery Policy and internal whistleblowing policy;
  • Continue to promote our corporate social responsibility policy.

In the last 12 months the Group can report the following:

  • We have carried out a risk assessment of our direct and indirect Supply Chain to create a heat map identifying areas of vulnerability for further action which is recommended.
  • We have delivered 3 E-Learning modules via Astute training to provide our employees with the necessary tools to identify Modern Slavery risk factors in our Supply Chain.
  • We have had no suspected incidents of Modern Slavery reported directly to us or via our whistleblowing policy.
  • We have refreshed all terms and conditions of purchase to reflect current legislations.
  • Adopted Chas Premium Plus for on boarding of all subcontractors which includes Modern Slavery questionnaire as this is considered best practise.
  • We have implemented a new system, Initiafy, for the onboarding process for all office and site-based operatives including subcontractors providing additional checks.

Responsibility

The Group’s Chief Executive Officer has overall responsibility for ensuring compliance with our legal and ethical obligations in respect of Modern Slavery and maintaining our internal policy. 

Tim Beale

Chief Executive Officer

November 2019

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