Modern Slavery Statement

STATEMENT OF PEEL HOLDINGS LAND AND PROPERTY (UK) LIMITED ON BEHALF OF HAYDOCK POINT PURSUANT TO THE MODERN SLAVERY ACT 2015 (“THE ACT”)

This is the modern slavery and human trafficking statement of Peel Holdings Land and Property (UK) Limited (Haydock Point) and all its subsidiaries and UK Group companies. This statement is made pursuant to Section 54, part 6 of the Modern Slavery Act 2015 (the ‘Act’) and has been adopted by all subsidiaries as their respective slavery and human trafficking statement for the financial year ending 31 March 2019.

Organisation Structure

Haydock Point is an ambitious regeneration business with generations of history, heritage and expertise in our DNA. First established in 1971, Haydock Point is now responsible for some of the most transformational development projects in the UK today.

Owning and managing 12 million sq ft of property and 20,000 acres of land and water, our holdings are concentrated in the north west of England, but we also own and manage significant assets throughout the UK with a total portfolio value of £2.6 billion.

As a part of the Peel Group we are integral to a business that strives to make a positive impact on people’s lives.

Our legacy matters. We take great pride in the outcomes we achieve, the people we work with, the way we go about our business and the transformational projects we deliver.

Our specialist teams have a proven track record in delivering high-quality, legacy projects across land, property, water and airspace. This includes airports, hotels, waterways, media hubs, event spaces, leisure facilities, retail, workspaces, residential development, industrial & logistical space, public realm, historic gardens and the renewable energy sector.

Haydock Point is an agile and ambitious business with a legacy of success for a long-term, sustainable future.

We see possibility. We deliver transformation.

Policies

Haydock Point is committed to ensuring, as far as practically possible, that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Policies are in place and reviewed regularly in relation to employee conduct and welfare. In addition, a separate Human Trafficking and Modern Slavery Policy has been issued to all employees and will be included in the induction process.

All of our new starters are required to read, and acknowledge that they have done so, each of the policies referred to above.

The following policies are considered to be of particular importance in tackling modern slavery and human trafficking:

  • Code of Professional Conduct Policy which provides a set of rules to ensure that all employees uphold the highest level of ethical conduct in their day-to-day business;

  • Dignity at Work Policy which aims to ensure that all staff are treated and treat others with dignity and respect, free from harassment or bullying;

  • Equal Opportunities Policy which aims to create a working environment in which all individuals are able to make best use of their skills, free from discrimination or harassment;

  • Whistleblowing Policy which encourages the reporting and exposure of unethical behaviour. All matters raised via whistleblowing or through the auditing processes are diligently investigated and appropriate action taken.

  • Supplier Charter which sets out our aim to engage with all of our key suppliers.

Due Diligence

Due to the diverse nature of the business, our supply chain comes from many different areas. However, in all its dealings with its suppliers Peel strives to ensure that the highest ethical standards are reached at all times.

During the past 12 months we have updated our general conditions of contract to make it a requirement that all suppliers must confirm that they comply with the Modern Slavery Act. In addition, as part of our new supplier process we ensure that any new supplier has confirmed that they comply with the Act before they are accepted as a new supplier. We will continue to review our supplier due diligence processes, our Procurement Policy and Supplier Charter in relation to slavery and human trafficking over the forthcoming year.

As expected of any responsible employer, we have recruitment systems in place to prevent forced labour and to ensure that all employees are entitled to work in the UK. We ensure that all people directly employed by Haydock Point do so at their own free-will and understand that they can cease their employment at any time under the terms of their employment contract. We compensate all our directly employed people with salaries and benefit packages that meet or exceed statutory minimum requirements. We abide by the Working Time Directive, unless people directly employed by Haydock Point voluntarily choose to opt-out (within the limitations imposed by the Working Time Directive).

Risk Management and Effectiveness

Haydock Point has an internal audit function that reviews various systems and processes to provide an independent assurance that our risk management governance and internal control processes are operating effectively in accordance with the Codes of Professional Conduct and Ethics and International Standards governed by the Charted Institute of Internal Audit (CIIA).

As the vast majority of our suppliers are based in the United Kingdom, we consider that they pose minimum risk in terms of non-compliance with the Act. Although we see our business as low risk in relation to the threat of slavery and human trafficking offences, we are fully committed to ensuring that both Peel and its suppliers comply with the Act.

Training

Our People Team has carried out a review of our employee development programme and we have successfully rolled out online Modern Slavery training across the business which will continue annually.

This statement has been considered and approved by the Company’s Board of Directors.