Modern Slavery Act
Modern Slavery Statement 2020/21
This statement has been published in accordance with the Modern Slavery Act 2015 (the “MSA”), pursuant to Section 54(1), Part 6. It sets out the steps taken by Argent (Property Development) Services LLP (“ASLLP”) during year ended 30 April 2020 to prevent modern slavery and human trafficking in its business and supply chains. This statement will be reviewed and updated annually.
Our business and supply chains
ASLLP provides asset and development management services for the King’s Cross Estate in London and the Paradise Circus development in Birmingham City Centre. It also provides its personnel, assets and experience to Argent Related Services Limited which acts as the development manager for the Brent Cross Town and Tottenham Hale projects. ASLLP, through the asset and development management services it provides, is involved in the full development process: identifying sites, developing designs and obtaining planning permission, securing finance, project managing construction processes and, eventually, asset management.
ASLLP works with a wide range of advisors and suppliers who procure the consultants and materials required in the design and construction of its various projects including masterplanners, designers, construction and a range of other contractors and suppliers. Naturally, its supply chains are therefore fairly complex and include supply chains involving construction labour and materials. There are multiple levels of suppliers between ASLLP and the source of raw materials procured for construction processes on ASLLP’s projects. The construction processes inevitably involve a significant number of raw materials and personnel sourced by the relevant suppliers and contractors from multiple locations. Given the nature of ASLLP’s supply chains, it is inevitable that ASLLP relies heavily on the safeguarding processes of its main contractors and suppliers to ensure that human rights abuses and incidences of modern slavery don’t occur in the supply chain.
Policies and contractual controls
ASLLP has a zero-tolerance approach to human rights abuses and modern slavery. ASLLP’s direct contractual relationships are largely with professional services and advisory firms, and as such it considers the vast majority of its providers to be relatively ‘low risk’.
ASLLP’s standard appointment documentation requires suppliers and contractors to comply with all applicable legislation (which includes the MSA) and to undertake regular reviews of their own supply chains and practices and to monitor the related risks. ASLLP is involved in selecting appropriate contractors and suppliers and negotiating contracts on behalf of its project entities, and requires that contractual obligations are included which seek to ensure that those contractors and suppliers do not engage in modern slavery or use labour which is subject to human rights abuses.
Due diligence and audit of suppliers and supply chain
As part of its ongoing due diligence process, ASLLP reviews its list of its contractors and suppliers, and identifies those entities by reference to (a) whether they are considered to be of ‘higher risk; and (b) amount paid by ASLLP to the contractors and suppliers. ASLLP continues to work with its most regular professional advisors and consultants including architects, project managers, legal advisors and consultants to understand information regarding each supplier’s approach to dealing with modern slavery within its organisation.
ASLLP acknowledges that the Covid-19 pandemic poses potentially new and increased modern slavery risks in its operations and supply chains. ASLLP is actively monitoring these risks and will ensure that it monitors and adapts its processes as necessary to seek to protect against these increased risks.
Assessment of modern slavery risk within our supply chain
Although it considers the majority of its business operations and providers to be relatively ‘low risk’, ASLLP has identified that its greatest risk with respect to modern slavery remains within its supply chain. Accordingly, ASLLP will continue to focus its due diligence efforts in the coming years on ensuring that its suppliers remain compliant with the MSA legislation.
Modern slavery training
ASLLP has commenced a Modern Slavery Act training programme for all relevant members of staff.
Further steps to prevent modern slavery in supply chains
Over the course of the year, ASLLP has taken the following steps to further prevent modern slavery in its supply chains:
- it has taken steps to ensure that it only enters into commercial relationships with companies who share its values and standards (particularly with respect to ethical labour standards); and
- it requires all new suppliers tendering for work with ASLLP or its project entities to provide details of its policies on slavery and human trafficking and provide assurances that it does not (and nor does any entity within its own supply chain) engage in slavery or human trafficking or any associated activity.
Over the next 12-month period, ASLLP intends to:
- undertake a full review of its existing modern slavery processes in light of Covid-19 to ensure new and increased risks are fully understood and processes are in place or adapted to tackle these;
- review its supply chain in further detail to gain a better understanding of the origin of raw materials procured in construction processes and the background of workers in the raw materials supply chain. The overall objective being to identify risk and implement actions to reduce the risks of modern slavery;
- encourage a culture of whistleblowing within its supply chain, including the provision of foreign-language awareness posters at all project construction sites;
- review and implement additional training for all staff in roles which are most likely to be exposed to potential victims of modern slavery; and
- publish an Anti-Slavery Policy and require its suppliers to confirm adherence with this.
Assessment of effectiveness in preventing modern slavery
ASLLP will continue to review and evaluate the effectiveness of its measures throughout the upcoming year, taking into consideration: staff and supplier training levels; the degree of suppliers’ compliance with ASLLP’s policies; any incidents of modern slavery within ASLLP’s supply chain; level of communication between ASLLP and its suppliers (and the same between providers and their sub-suppliers); and evidence of steps taken by ASLLP to address risks identified during its due diligence process.
No instances of modern slavery have been identified by ASLLP (in its supply chain) during the year.