Modern Slavery and Human Trafficking Statement

This statement is made in line with section 54(1) of the Modern Slavery Act 2015 and sets out Audley Group’s actions to understand all potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our own business and supply chains.

As part of the, property, hospitality and care sectors, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking throughout our entire business. We are absolutely committed to preventing slavery and human trafficking in our business activities, and to ensure that our supply chains are free from slavery and human trafficking.

 

Organisational Structure

This statement covers the activities of Audley Group Limited and all subsidiary companies.

The Audley Group builds and operates retirement villages and operates care branches throughout the UK. We buy land, secure detailed planning consent and then build, sell and manage the high-quality retirement villages that we create. An important part of our operations once a village is created is to establish a domiciliary care business through which we provide care to our owners and to the neighbouring public.

The Audley Group currently operates within the UK only. We directly employed close to 600 people in the period ending 31 December 2017 as well as contracting with agency and subcontractor companies. Our revenue for the period was £89.2million

Supply Chains

We do not directly employ the workforce that constructs our villages, but indirectly engage them through our construction contractors. We use reputable, established contractors and carry out due diligence before engaging them to ensure they share the Audley Group ethics and values. We use a small number of suppliers in the construction process and this allows us to understand well their own policies and procedures as regards modern slavery and human trafficking. This knowledge minimises the risks of us, through our contractors, having any involvement in modern slavery and human trafficking.

The hospitality and care sectors may also use casual and temporary workers. We directly employ our village team members and carers and no employee is offered a zero hours contract unless they request it. We carry out detailed checks on all our employees, including enhanced DBS checks prior to commencement of permanent employment. Where temporary cover is occasionally used our policy is to use reputable firms that carry out right-to-work checks.

Responsibility for our anti-slavery initiatives including policies, risk assessments, investigations/due diligence and training ultimately lie with the Board of Directors.

Related Policies

The Audley Group operates the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

Whistleblowing Policy: We encourage all our employees, workers, customers and other business partners to report any concerns related to our direct activities or supply chains. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can contact an external and anonymous 24 hour helpline.

Anti-bribery policy: Our policy confirms Audley’s zero tolerance of bribery and corruption and extends to all business dealings and transactions. All employees, officers, agents or consultants or any persons or companies acting for Audley or on our behalf are expected to adhere to this policy.

Employee Code of Conduct: Our code makes clear to employees the actions and behaviour expected of them when representing Audley. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.

Health and Safety Policy: Our policy on health and safety aims to develop a culture that is committed to the prevention of ill health and injuries to our employees and others that may be affected by our operations.

Employee Handbook: Our employee handbook provides information to all colleagues on their statutory rights, inclusive of sick pay, holiday pay and other benefits that they may be entitled to by virtue of their employment. No employee is offered a zero hours contract unless they request it.

Future steps

It is important that our policies and procedures relating to the prevention of modern slavery and human trafficking evolve in line with best practice and changing circumstances. To that end we will be taking the following steps to ensure we are compliant with UK legislation.

  • Write to all suppliers asking them to reconfirm to us that there is no modern slavery or human trafficking in their supply chains or business and that they have adequate systems in place to identify, assess, monitor and mitigate potential risk areas in their business and supply chains and to protect whistle blowers.
  • Widen the scope of our whistleblowing policy to specifically include reporting on modern slavery and human trafficking.
  • Introduce further training on health and safety for all employees.
  • Commence the development of a formal CSR policy including a clear objective that we will seek to ensure modern slavery is not taking place within our business or supply chains.
  • Commence the development of a formal modern slavery policy.
  • Introduce training on modern slavery and human trafficking for all employees.

 

Board Approval

This statement has been approved by the Board of Directors, who will review and update it annually, and signed on its behalf by:

Nick Sanderson

Chief Executive Officer