This Modern Slavery Statement (this “Statement”) has been published by Annington Limited (“Annington”, the “Company”, “we”; “us”) collectively with its group companies, in accordance with Section 54 of the UK Modern Slavery Act 2015 (2015 c.30) (the “UK Act”). This Statement has been adopted by Annington’s subsidiary companies.

 

About Annington

Our Values

‘Modern slavery’ is defined by Anti-Slavery International as ‘when an individual is exploited by others, for personal or commercial gain, and loses their freedom. It includes but is not limited to human trafficking, forced labour and debt bondage.’

Annington Limited strictly prohibits any form of slavery, human trafficking, forced labour or other comparable environments or practices. We respect the human rights of all individuals are committed to implementing and maintaining systems and controls to uphold fair and safe working environments. Annington expects everyone working with us or on our behalf to implement and maintain safe working conditions.

We strictly prohibit the use of modern slavery and human trafficking in our operations and supply chain. We are committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains.  We expect that our suppliers will hold themselves and their own suppliers to the same high standards. 

With the regular review of our Company policies and practices, we seek to recognise, prevent and abate the risk of modern slavery throughout our operations and supply chains.

Our Business

Annington has a strong track record as a major investor in UK Residential Real Estate, with nearly 30 years’ experience of refurbishing, developing and managing residential real estate at scale. We pride ourselves in supporting and making a positive impact on the communities we work in.

As owners of the Ministry of Defence’s Married Quarters Estate (MQE) for 28 years, we have refurbished and repurposed over 20,000 homes affordable family homes. By doing so, we enabled thousands of families all over the UK to own their home for the first time.

Having sold the MQE portfolio in January 2025, Annington is continuing to build on its unrivalled expertise in the Private Rented Sector and remains committed to playing a part in addressing the UK’s current housing shortage.

 

Our Corporate Structure & Supply Chain

Annington Limited is incorporated in the United Kingdom and as of the date of this statement, is the ultimate parent company for the group. The Company conducts our business through the group entities, a list of which are on page 5. All our employees are based in the UK.

Due to the varied nature of the Annington business, the Company often engages with and maintains a third-party supplier list to refurbish and build properties as well as other tasks across the business. 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 exist in relation to our contracting activities and the possible use of trafficked labour on-site or within the Company’s supply chain. When considering the risks associated with the various areas of the business, the Company’s established policies covering Anti-Slavery and Human Trafficking, Whistleblowing, Financial Crime form the backbone of the review. It is vital to the Annington business that we maintain high standards and close relationships with our suppliers to mitigate these risks.

 

Preventing Modern Slavery

In line with the UK legislation, this Statement presents Annington’s risks and the actions we have taken to prevent and mitigate the risks of human trafficking and modern slavery. This Anti-Slavery & Human Trafficking Statement is the annual review and an update from our 2024 Statement.

New Supplier Onboarding

Annington implemented a new supplier onboarding system in 2024-2025. As part of this, the Company requires all new suppliers engaged by Annington to undertake a questionnaire as part of our onboarding process. This process involves the completion of a bespoke form for disclosure of key information relating to each supplier’s business practices. Any other building contractor or property agent that is managed on behalf of Annington is asked to confirm they have the appropriate policies and procedures in place.

We have invested a large amount of time into this process to ensure our suppliers adhere to our zero-tolerance approach to modern slavery and human trafficking. As such:

  • All new suppliers complete a mandatory assessment. This is irrespective of the risk level they are deemed to be.
  • We are working to onboard existing suppliers using this system to reach a standardised process across our suppliers.
  • Suppliers are asked about several controls and processes, including:
    • The requirement to provide a copy of modern slavery or anti-slavery policy or statement, or similar, should they meet the eligibility requirements to need one.
    • To confirm compliance with the annual reporting requirements that are noted in Section 54 of the Modern Slavery Act.
    • The process they follow to assess and manage any risks of forced labour that may be present in their business and/or supply chain.
    • To provide information of any KYC process they undertake on prospective suppliers or sub-contractors.
    • To provide details of compliance with other relevant legislation.
  • A decision is taken as to whether a supplier is onboarded. This is based on the supplier’s individual residual risk level through the consideration of factors such as their anti-slavery process.

 

Recruitment and Training

We deem Annington’s operations to be low risk. However, we manage the risk of modern slavery by ensuring the people we employ have the right to work and that their basic rights as workers are protected. All staff are required to complete modern slavery awareness training to ensure that they understand the potential risks facing the Company. We are also able to suggest suitable Anti-Modern Slavery Training to any of our key building contractors to raise awareness around modern slavery and human trafficking.

 

Response and Escalation

If there is a suspicion that modern slavery or forced labour is taking place either within the Company or within our supply chain, an employee must notify their line manager as soon as possible. This should then be escalated accordingly to either the Head of Legal, Chief Financial Officer or the Chief Executive Officer. If a third-party suspects modern slavery or forced labour is taking place, they are also able to report this. All reports will be managed confidentially and with caution.

In addition, if upon investigation, there appears to be no forced labour taking place, the individual who reported this will not be penalised in any way. Annington aims to inspire openness and honesty, and will support anyone who raises genuine concerns under this Statement, even if they turn out to be mistaken.

Annington maintains our Whistleblowing Policy which notes a simple and confidential process to follow to report any suspicious activity or concerns of the Company. This Policy also details the safeguarding protections that are provided to a whistleblower.

Any employee who infringes this Statement will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. Annington may terminate its relationship with third party suppliers if this Statement is not complied with.

 

Our Team

We have a dedicated team that involves the below representatives from across the Annington business:

Sarah Jury – Head of Legal

Philip Allen - Director of Project & Sales

Charlotte Marinos - Head of Project Management

Ian Rylatt - the Chief Executive Officer, with responsibility to the Annington Board for oversight of the Act across the Group.

 

The Future

Annington strives to continue to eliminate modern slavery and human trafficking. We are conscious that a statement is not the only way to eliminate such a complicated issue. As a result of this, we are committed to fostering ways to improve our systems internally to identify, manage and mitigate the risks related to modern slavery in our supply chains and operations.

 

This statement has been approved by the Company’s Board of Directors (“Board”) as of July 2025.

 

Annington Limited Subsidiaries

Annington (DA) Investment Limited

Annington Developments Limited

Annington Developments (Holdings) Limited

Annington Funding plc

Annington Guarantee Limited

Annington Homes Limited

Annington Management Limited

Annington Nominees Limited

Annington Property Limited

Annington Property (No.2) Limited

Annington Receivables Limited

Annington Rentals Limited

Annington Rentals Management Limited

Annington Rentals (No.2) Limited

Annington Rentals (No.3) Limited

Annington Rentals (No.4) Limited

Annington Rentals (No. 5) Limited

Annington Rentals (No.6) Limited

Annington Rentals (No.7) Limited

Annington Rentals (No.8) Limited

Annington Rentals (Holdings) Limited

Annington Subsidiary Holdings Limited

St Andrew’s Park Triangle (Uxbridge) Management Company Limited