Modern Slavery Act Statement
MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR THE FINANCIAL YEAR ENDED 31 DECEMBER 2022
This statement is made by GLP UK Management Limited (“GCP UK”). GCP UK is registered at Companies House with company registration number 11065864 and has its principal place of business in London, with affiliated offices across Europe.
This statement is made by GCP UK pursuant to section 54, Part 1 of the Modern Slavery Act 2015 (the “Act”) and references to “we”, “us”, “our” or “the Company” are to GCP UK. It constitutes GCP UK’s slavery and human trafficking statement for the financial year ended 31 December 2022 and sets out the steps taken to ensure that slavery or human trafficking did not take place in our business and supply chain during this financial year.
BUSSINESS & SUPPLY CHAIN
Our business is within the real estate sector and our supply chain particularly for our development projects involves high volumes of construction. Our supply chain often involves several entities or projects performed by a prime contractor with a series of sub-contractors. We can only exercise control over our relationship with our contractual counterparty; those persons who contract with that counterparty will be performing services for the counterparty and not for other persons in the contractual chain.
The principal way in which we approach modern slavery risks in our business and supply chain is by way of the procedures as set out in our Construction Procurement Policy, our Third Party Anti-Bribery and Corruption Due Diligence Policy, our Anti-Money Laundering/ Anti-Bribery and Corruption Policy and our Code of Business Conduct and Ethics (the “Code”) (together the “Policies”). The Policies are part of our efforts to conduct our business in a manner that is free from slavery and human trafficking.
We have a commitment to conduct our business and all our relationships based on integrity. This commitment is contained in our Code.
During this financial year we:
- Reviewed our Policies to ensure our continued commitment to:
- implementing and enforcing effective systems and controls designed to eradicate modern slavery in our business and supply chains; and
- being transparent in doing so through our disclosure obligations under the Act.
- Operated a due diligence protocol that includes anti-slavery considerations embedded within our Third-Party Anti-Bribery and Corruption Due Diligence Policy, which applies when engaging or renewing third party suppliers. This protocol includes a modern slavery due diligence questionnaire for each construction contract in order to mitigate modern slavery and human trafficking risks within our construction supply chain; and
- Encouraged colleagues, our suppliers and business partners and anyone else to whom our Policies apply to report any concerns about modern slavery related to its businesses and direct supply chains in accordance with our Policies. We provide a whistle blowing hotline (operated by an independent third party provider) which is available to colleagues, consultants and suppliers.
Based on the above, we consider that our policies and procedures are transitioning towards a reasonable level of assurance of effectiveness in eradicating modern slavery and human trafficking in our business and supply chain. As a business we continue to monitor the need for any further action.
Approved by and signed on behalf of the Board of Directors of GLP UK Management Limited on 27 June 2023.