Modern Slavery Act
Modern Slavery Statement 2019/20
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 31 March 2019 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 has been in operation since 2012 and employs the staff who operate the business of King’s Cross Central Limited Partnership (“KCCLP”). ASLLP acts as the asset manager and development manager for the King’s Cross Estate in London and the Paradise Circus development in Birmingham City Centre. It also acts as the development manager in respect of the new developments planned by Argent Related Services LLP at Brent Cross South and Tottenham Hale.
ASLLP works with a vast range of advisors and suppliers to procure the consultants and materials required in the design and construction of the King’s Cross Estate, Brent Cross South and Tottenham Hale including masterplanners, designers, construction and a range of other contractors and suppliers. As a result, its supply chains are often very complicated (particularly those involving construction labour and materials); there are often multiple levels of suppliers between ASLLP and the source of raw materials that enter the procurement process. Consequently, identifying and handling all related risks is a very challenging undertaking. ASLLP therefore relies heavily on the safeguarding processes of its main contractors and suppliers in ensuring that human rights abuses and incidences of modern slavery don’t occur in the supply chain.
Policies and contractual controls
ASLLP is against the use of forced labour, child labour and human trafficking within its business and supply chain and it reserves the right to terminate its relationship with any supplier in the event of the discovery of any activity of this nature.
Going forward, ASLLP will require all suppliers and contractors to adhere to (and confirm compliance with) its MSA Policy, and will encourage them to adopt a similar policy within their respective organizations. ASLLP’s standard appointment documentation already requires suppliers and contractors to comply with all applicable legislation (which includes the MSA) and will be amended to require suppliers to undertake regular reviews of their own supply chains and practices and monitoring of the related risks. In the event that any breach of ASLLP’s MSA Policy is identified, the supplier in question must promptly notify ASLLP of such occurrences.
Due diligence and audit of suppliers and supply chain
As part of its due diligence process ASLLP has compiled a list of its suppliers, identifying and prioritising those entities which submit the highest value and most regular invoices. ASLLP has selected 10 of its most regular professional advisors and consultants including architects, project managers, legal advisors and consultants and will contact these providers to request information regarding each supplier’s approach to dealing with modern slavery within its organisation.
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 is 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 begun to increase its focus on modern slavery within its business operations and supply chains. It will now work towards formulating its own Anti-Slavery Policy. In addition to familiarising all employees and suppliers with these documents (and requiring suppliers to confirm adherence with them), ASLLP will establish a Modern Slavery Act training programme for all members of staff.
Further steps to prevent modern slavery in supply chains
Over the course of the coming year, ASLLP will look to take the following steps to further prevent modern slavery in its supply chains:
- seek to identify and enter into commercial relationships with companies who share its values and standards;
- require any new supplier tendering for work with ASLLP 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;
- refuse to enter into commercial relationships with entities knowingly involved with slavery or human trafficking;
- conduct annual audits of its main contractors and suppliers and review their controls and established processes, and assess their compliance;
- encourage a culture of whistle-blowing within its supply chain; and
- introduce an induction and periodic training programme for all staff of ASLLP.
Assessment of effectiveness in preventing modern slavery
ASLLP will review and evaluate the effectiveness of its measures throughout the upcoming year, taking into consideration: staff and supplier training levels; degree of suppliers’ compliance with ASLLP’s policies; 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.