This statement is made in accordance with section 54 (1) of the Modern Slavery Act 2015 (MSA) by Inland Homes Plc and each of its group companies for the financial reporting period to 30 September 2020.
Inland Homes Plc has a zero-tolerance approach to modern slavery within in our business operations and supply chain. In this statement, we set out our approach to meeting the requirements of the Modern Slavery Act.
Inland Homes are established land professionals and Housebuilders. We focus on building residential and mixed-use communities for sale, or for partner organisations, across the south and south-east of England.
Our land portfolio has a gross development value exceeding £3.1bn, with a land bank of more than 11,000 plots of which nearly 2,500 have planning consent.
Our supply chain includes infrastructure and construction contractors, sub- contractors, consultants and professional service advisors. We also work closely with a range of stakeholders including housing associations, housebuilders, funders, local and planning authorities, regulatory bodies, Homes England and joint venture partners.
The activities of the Group and its joint ventures are undertaken solely in the United Kingdom and all the Group’s companies and joint ventures have their registered office in England. Inland Homes Plc is an AIM listed organisation.
The Group regularly reviews it policies and procedures to ensure they remain appropriate. The following policies support our approach to compliance with the MSA and review is mandatory for all staff.
During the year, the Whistleblowing Policy and associated managerial guidance were reviewed by the Audit Committee and approved by the Board.
The Group intended to roll out its Anti-Slavery and Human Trafficking policy during the year and guidance will be available to ensure the implications for individuals and the Group are clear.
This year we reviewed and updated our Employee Code of Conduct (the Code). The Code sets out the standards expected of all our employees in upholding our values.
Through our sustainable procurement policies, we set out our commitment to specify sustainable materials and work with supply chain partners that demonstrate a high regard for and promote social responsibility. Our Sustainable Procurement Strategy is explicit in the requirement for all members of our supply chain regardless of size, to work to ensure modern slavery does not occur in their supply chain.
Risk assessment and due diligence process
With the impact of Covid-19 on the world we are conscious that businesses are suffering and the risks of modern slavery within any supply chain are increased. We are in the process of introducing new software that will allow us to analyse our suppliers and subcontractors more effectively. This will allow us to better understand areas of high risk. This work is being done alongside our routine due diligence. We engage with all current and future suppliers to ensure their approach to preventing modern slavery is in line with our expectations and those of the legislation in place. Our engagement process with both suppliers and subcontractors demonstrates our commitment to sustainable procurement, using our stronger together process which forms part of our Quality Management System. We have secured a digital bridge with Constructionline, who audit our sub-contractors’ compliance with the MSA amongst other legislation on our behalf.
Training and staff awareness
Our employees are aware that Inland operates a zero-tolerance approach to modern slavery in our business and supply chains. A number of e-learning training modules which addresses modern slavery, human trafficking and whistleblowing are included in our employee induction process and are mandatory for all staff. The Group is a signatory to the Gangmasters & Labour Abuse Authorities Construction Protocol (GLAA) and utilises the support tools available. We are in process of introducing the GLAA induction into our site inductions.
Developing and implementing our Environmental, Social and Governance (ESG) strategy is a key objective for the Group this year. A cross-departmental working party has been established and tasked with driving this agenda forward. Our approach to meeting the requirements of the MSA, managing the risk presented by modern slavery to the Group and its supply chain will fall under the remit of the working party, with a clear reporting line to the Board.
We will continue to build on our engagement with the Gangmasters & Labour Abuse Authorities Construction Protocol, which is a joint agreement aimed at establishing collaboration within the construction industry. The Protocol commits signatories to work in partnership to protect vulnerable workers, share information to help stop or prevent exploitation and commit to raising awareness within the supply chain.
We will further utilise the valuable resources available through ‘Stronger2gether’, a multi-stakeholder initiative set up to support construction companies in tackling modern slavery, providing a safe platform and support network for sharing challenges and good practice with peers and experts.
With an increasing property portfolio, we recognise the importance of monitoring “onsite” activity by our employees and our suppliers, to mitigate against the risk of slavery or trafficking taking place on our sites, particularly those which are more remote. We have started a process of modern slavery awareness for our site and procurement teams. The intention is to expand this process building an awareness campaign into our standard practices both on and off site.
This statement and the associated policies remain subject to annual monitoring and review.
Stephen Wicks CEO on behalf of the Group Board Inland Homes plc 2020