This statement is made pursuant to s.54 of the Modern Slavery Act 2015, in respect of the financial year ending 31 December 2021.
It sets out the steps that Almacantar Group Limited and its relevant subsidiaries (in 2021, Almacantar Limited and Almacantar Marble Arch Construction Limited) (the “Companies”) have taken - and are continuing to take - to ensure that modern slavery or human trafficking is not taking place within our business or supply chains. We are committed to acting in an ethical manner, with integrity and transparency in all business dealings.
Almacantar Group Limited is the holding company of the Almacantar property investment and development group. The group specialises in large-scale, complex investments in Central London, with the potential to create long-term value through development, repositioning or active asset management.
Our modern slavery risk areas
The group had 42 direct employees as at 31 December 2021 (all of whom are employed by Almacantar Limited) and so relies heavily on external suppliers to undertake its commercial activities. These commercial activities include the redevelopment, construction and active management of real estate assets.
We consider our most significant risk areas in relation to slavery and human trafficking are in our construction supply chains, which are multi-layered and require manual labour resources.
Steps taken during 2021
During the course of 2021, we continued to promote awareness of the Business Ethics Policy in our Staff Handbook, which educates staff about the warning signs of modern slavery and human trafficking. The policy sets out the steps that employees should take to prevent modern slavery and human trafficking, as well as how to raise a concern.
This policy requires staff to carry out a risk-based assessment of any new supplier. For suppliers and contractors that are considered higher-risk with regards to modern slavery and/or human trafficking, the following steps should be taken:
- questioning the supplier about the systems they have in place to prevent modern slavery and human trafficking; and/or
- including an express contractual provision in supplier contracts requiring adherence to current modern slavery and human trafficking legislation.
As stated above, the Companies’ most significant risk area in relation to slavery and human trafficking are considered to be in their construction supply chains.
During 2022, we are continuing to ensure employees monitor the risk of modern slavery and human trafficking in our supply chains, take appropriate measures and understand what to do if they have concerns.
Approval for this statement
This statement was approved by the Board of Directors on 1 March 2022.