Slavery and human trafficking statement
The Places for People Group (the “Group”) operates across the UK through a number of operating subsidiaries. We are one of the largest property and leisure management, development and regeneration businesses in the UK. We own or manage more than 198,000 homes and 127 leisure centres and have assets in excess of £4.4 billion. We provide our services through the efforts of more than 12,300 staff in the UK.
Our services are delivered through 20 principal companies although we arrange our activities so that clients, customers and staff regard all parts of the Group as a single business.
The Group has noted the requirements of the Modern Slavery Act 2015 (the "Act"). This statement is made on behalf of the Group parent, Places for People Group Limited (company number 03777037), and the Group as a whole. The following subsidiaries in the Group are required to make their own statement under the Act and have adopted this statement:
• Places for People Developments Limited (company number 04086030);
• Places for People Homes Limited (company number IP19447R);
• Places for People Leisure Limited (company number 08363432);
• Places for People Living+ Limited (company number IP20014R);
• Allenbuild Limited (company number 01248351);
• Derwent Housing Association Limited (company number IP18127R);
• MDH (Group) Limited (company number 09096398);
• Millwood Designer Homes Limited (company number 02704499);
• PfPL (Holdings) Limited (company number 04832063);
• Zero C Holdings Limited (company number 06540829);
• Chorus Homes Group Limited (company number 04782653);
• Chorus Homes Limited (company number RS007813); and
• Castle Rock Edinvar Housing Association Limited (company number SP1767RS).
Our core businesses
We operate across the whole of the property value chain from initial procurement of sites, through planning and project management to the delivery of high quality places with supporting infrastructure and strong management.
We deliver services to a range of stakeholders including tenants, landlords, housebuyers, local authorities, investment fund managers and leisure centre users.
Our supply chain
Our large and varied Group business offering is reflected in the breadth and complexity of our UK supply chain that has more than 2,000 established members. We engage with a wide variety of organisations for a broad range of goods and services - primarily corporate, construction and property related, but also some more specialist requirements.
Our supply chain members are diverse not only in the goods and services they provide, but also in the size and structure of their organisations - from the very small to multi-nationals. We encourage smaller businesses to apply to join our supply chain in order to promote local business initiatives in the UK.
Our policies to resist modern slavery and human trafficking
We have reviewed our existing policies and procedures in light of the Act. We are confident that our policies promote good behaviour among our colleagues at work and within our supply chain. Our policies and procedures are kept under review to make sure that they reflect the changing shape of the Group and of the needs of the people and markets it serves in the UK.
In our own businesses
The policies that we consider give us strength in avoiding modern slavery or human trafficking under the Act in our businesses are:
• Recruitment & Selection Policy;
• Health & Wellbeing Policy;
• Equality, Diversity & Inclusion Policy;
• Whistleblowing Policy;
• Behaviour at Work Policy (which covers conduct at work including fraud response, gifts/hospitality and personal interests); and
• Secondary Employment Procedure.
Our whistleblowing policy makes clear that a report of concern in relation to modern slavery or human trafficking can be made under the protection of the policy.
In our supply chain
We are determined that there shall be no modern slavery or human trafficking in our supply chain. Our Supply Chain Code of Conduct and Sustainable Procurement Policies evidence our commitment to act ethically and with integrity throughout our business relationships and all suppliers, no matter how long-standing, are required to abide by them. The code and the policies are kept under review to make sure that they reflect the changing shape of the Group and of the needs of the people and markets it serves in the UK.
We continue to strengthen the relationship with our supply chain members through enhanced enterprise resource systems. These give us better information about more suppliers and make us better able to apply centralised standards across the Group.
Our code reflects the requirements of the Act. We have published it to our supply chain members through our on-line channels to ensure that all suppliers are aware of our expectations. As part of a selection questionnaire when tendering, adherence to the act is a mandatory requirement for any new suppliers working for the Group.
In accordance with best procurement practices set out by the Chartered Institute of Purchasing and Supply (CIPS), we perform audits at random on supply chain partners that includes the reviewing of policies, inspections of their buildings and interviewing staff as to pay and working conditions. We do this as a positive and proactive way to ensure the supply chain are meeting their requirements in relation to the Act.
We have contracts with supply chain members and in many cases those contracts are for several years' duration. We have introduced a contractual requirement for suppliers that they do not engage in any activity that is contrary to the Act. Where a contract has been renewed during the year or any new contract has been entered into, that contract term has been applied. Over time, we will achieve the inclusion of the contractual requirement in all supplier relationships. Every supplier (whether on a new contract or one formed before the Act came into force) knows that we expect them to avoid modern slavery practices because they are required to abide by the code for supply chain partners.
Training and continuing vigilance
We have discussed the Act, its purpose and the Group's attitude to it at a Group board meeting. We have alerted our senior managers to it and challenged them to continue to consider where the risk of modern slavery or human trafficking may arise in their parts of the Group's businesses. We have provided guidance to our procurement team members on the need to avoid those risks and on possible indicators of them in the supply chain. We will continue to enhance the assurances we seek from supply chain members as to their avoidance of modern slavery and human trafficking.
This statement is made pursuant to section 54(1) of the Act for the financial year ending 31 March 2020 (1 April 2019 to 31 March 2020). It has been approved by Places for People Group Limited’s board of directors on 27 May 2020 and the boards of directors of each of the Group’s subsidiaries required to make a statement under the Act.
Signed by DAVID COWANS, in his capacity as Group Chief Executive of Places for People Group Limited.
Date: 27 May 2020