Annington Limited – Modern Slavery and Human Trafficking Statement
ANNUAL SLAVERY AND HUMAN TRAFFICKING STATEMENT
The 2015 Modern Slavery Act ('the Act') came into force on 29 October 2015. This statement is made pursuant to Part 6 of the Act and sets out the steps Annington Limited (‘the Company’) and its subsidiaries have taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of the business.
Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Victims are coerced, deceived and forced against their free will into providing work or services. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.
Within Annington’s core operations, the scale of refurbishment work required to the properties varies from site to site and is greatly dependent on the condition in which they are handed back by the MoD. In order to manage this and the fact that the release of properties to Annington is entirely at the discretion of the MoD, Annington has determined that the most effective and efficient method of procuring the refurbishment work is to outsource it to pre-selected contractors and suppliers.
Annington conducts an annual review of its business and operations including risks associated with modern slavery. This work identified that Annington remains a low risk business but that the areas of highest risk exists around our contracting activities and the possible use of slave / trafficked labour on site or within the Company’s supply chain. As part of this process the following policies were reviewed:
During the year Annington ensured that it remained compliant with the legislation by ensuring all new contractors completed the updated pre-qualification questionnaire which covers modern slavery legislation and that all engaged contractors certify that they have the relevant policies and procedures in place and that they will abide by the Annington Supplier Code of Conduct.
In line with the Company’s corporate governance arrangements the Board of Annington Limited have approved the:
Policy on Slavery and Human Trafficking;
Annington has taken steps to raise awareness of slavery and trafficking issues amongst its staff and contractors through the introduction of the policy documents listed above. We are also taking steps to introduce training to the key members of staff working in our property team, to assist them to be able to spot signs of slavery and trafficking and to understand the risks involved.
Annington will continue to monitor and assess its performance in this area through the following measures:-
Reviewing our progress in entering into communications with contractors to raise awareness of the Modern Slavery Act and our Supplier Code of Conduct.
Continuing to focus on our supplier due diligence process to ensure that we engage appropriately with any new suppliers and contractors.
Annington strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain and is committed to implementing systems and controls and delivering training aimed at ensuring that modern slavery is not taking place anywhere within its organisation or in any of its supply chains. The Property Director has responsibility for ensuring that the contractors and suppliers used in the refurbishment of properties comply with Annington’s policies, including Slavery and Human Trafficking. The Commercial Director has responsibility to the Annington board for oversight of the Act across the Group.
This statement represents Annington’s statement in accordance with Section 54 of the Modern Slavery Act 2015 for the financial year 1 April 2016 to 31 March 2017 and has been approved by the Board of Directors.
25 July 2017