Modern Day Slavery Statement – 2021

A) ORGANISATION
This statement applies to any company that is a subsidiary, holding company or affiliate (including any limited liability partnership) of Sellar Design and Development Limited (referred to in this statement as ‘the Group’). The information included in the statement refers to the financial year ending 31 December 2021.

B) ORGANISATIONAL STRUCTURE
The Group’s head office is based in central London, United Kingdom. Due to the nature of its business the Group also operates from a number of property development sites across the United Kingdom, primarily concentrated in Greater London. The labour supplied to the Group in pursuance of its operations is wholly carried out in the United Kingdom.

The Group operates in the property development and investment industry and therefore there is a very low level of seasonality to its operations.

C) SUPPLY CHAINS
The Group’s main supply chains include those related to provision of construction services and professional services such as architects, surveyors and other professional contractors. The Group generally appoints a main contractor to oversee and undertake construction work at its sites in the United Kingdom.

D) MODERN SLAVERY
Modern slavery can take various forms including servitude, forced or compulsory labour through mental or physical threats, and human trafficking, each involving the deprivation of a person’s liberty to exploit them for another’s personal or commercial gain. It is a crime and a violation of fundamental human rights.

E) COMMITMENT
The Group takes a zero-tolerance approach to modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Group understands that this requires an ongoing review of both its internal practices in relation to its labour force and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in its business or in its supply chains.

The Group does not enter into business with any other organisation in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Group in the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in United Kingdom.

The Group’s commitment to acting ethically and with integrity in all its business relationships and to tackling modern slavery is reflected in its Modern Slavery Policy.

F) MAIN SOURCE OF EXPOSURE
The Group considers its main exposure to any risks of modern slavery could exist in the provision of labour on construction sites. However, given the steps that the Group has taken to eliminate modern slavery and human trafficking in its supply chain (as detailed in part H of this statement), the Group considers its exposure to any incidents of modern slavery to be low.

G) IMPACT OF COVID-19
During the reporting period covered by this statement, the COVID-19 pandemic had taken hold. For several months, the UK was subject to restrictions on movement and lockdowns of society and the economy to prevent the transmission of COVID-19. This created several challenges for the Group including in preparing its Modern Slavery Statement, as it did for other businesses across the nation.

The Group concludes that the COVID-19 pandemic did not adjust the risk of modern slavery to a level above that which existed before the pandemic (set out at part F above). During the pandemic, the Group’s employees still had access to the grievance procedure to raise any concerns that they may have had and all Group employees that were required to self-isolate where it was not possible to agree a temporary period of homeworking, were paid Statutory Sick Pay.

The Group’s modern slavery risks were subject to the same monitoring procedures during the pandemic as at all other times.

H) STEPS
All Group employees and contractors are expected to conduct themselves with the highest levels of integrity and in full compliance with the laws and regulations that govern the Group’s business. This includes taking steps to prevent, detect and report incidents of modern slavery in any part of the business.

All Group suppliers are required to source goods or services from third parties that meet, as a minimum, country of origin standards for health, safety, working hours, pay and employment conditions. The Group has not, to its knowledge, conducted any business with any organisation which has been found to have involved itself with modern slavery.

In addition, the Group is taking the following steps to continue to ensure that modern slavery is not present in its business or any of its supply chains:
– carrying out due diligence processes and reviewing supplier contracts to ensure that forced, compulsory or trafficked labour is prohibited in supplier contracts and to include termination powers in the event that the supplier is, or is suspected to be involved in modern slavery;
– identifying, monitoring, and assessing the potential risks areas of its supply chains;
– undertaking impact assessments of its services in relation to potential instances of modern slavery;
– creating action plans to address any risks of modern slavery; and
– providing training to relevant employees to detect signs of modern slavery in the supply chain.

This statement constitutes the Group’s slavery and human trafficking statement for the financial year ending 31 December 2021 and is made in connection with the Group’s obligations under Section 54(1) of the Modern Slavery Act 2015.

The statement has been approved by the Board of Directors of Sellar Design and Development Limited and will be reviewed for each financial year.

Date of approval: 5th January 2022
Signed: Owen Dannatt, Chief Operating Officer

For and on behalf of Sellar Design and Development Limited