This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year. It sets out the steps taken by Wallacea for the financial year 2023/2024 to prevent modern slavery and human trafficking in its own business operations and supply chains.
Definitions
Wallacea considers that modern slavery encompasses:
- human trafficking
- forced work, through mental or physical threat
- being owned or controlled by an employer through mental or physical abuse of the threat of abuse
- being dehumanised, treated as a commodity, or being bought or sold as property
- being physically constrained or to have restriction placed on freedom of movement.
Commitment
Wallacea is committed to the principles in the Modern Slavery Act 2015 and commits to taking reasonable steps to tackle modern slavery and human trafficking within its business and supply chain.
Wallacea acknowledges its responsibilities in relation to tackling modern slavery and voluntarily commits to complying with the provisions in the Modern Slavery Act 2015. Wallacea is committed to acting ethically and with integrity and transparency in all business dealings and to safeguard against any form of modern slavery taking place within its business or supply chain. With this in mind, Wallacea understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
Wallacea 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 Wallacea in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. Wallacea strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom and in many cases exceeds those minimums in relation to its employees.
Our business and organisational structure
The main activity carried out by Wallacea is that of providing luxury retirement community properties in central London.
Wallacea employees work either remotely or from a central office in London. A number of central functions e.g. H&S, legal, IT are currently outsourced. Wallacea operates only in the UK.
Our supply chains
Wallacea’s supply chain consists of third-party suppliers, contractors and sub-contractors on whom Wallacea relies on to execute its development projects. The suppliers vary in size from larger corporations to individual tradesmen.
Potential exposure
Wallacea considers its main exposure to the risk of slavery and human trafficking to exist in using suppliers, contractors, and sub – contractors which are smaller businesses and not required in law to comply with the Modern Slavery Act 2015. To alleviate such risk Wallacea regularly reviews its list of suppliers to assess the risk of modern slavery.
In general, Wallacea considers its exposure to slavery/human trafficking to be relatively limited. It has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
Due Diligence Processes
Wallacea carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
Wallacea has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, Wallacea has taken the following steps to ensure that modern slavery is not taking place:
- a review of its supplier contracts to include termination powers in the event that the supplier is, or is suspected, of being involved in modern slavery
- created an action plan to address the risks of modern slavery
- communication of this policy to those working with Wallacea to ensure awareness and to embed a zero-tolerance policy towards modern slavery
Despite the perceived low risk of modern slavery or human trafficking in our operations or supply chain Wallacea is committed nonetheless to ensuring that its suppliers adhere to the same ethical standards as it does.
Policies and training
Wallacea has the following internal policies which further define its stance on modern slavery and require that Wallacea conducts its business in an ethical and transparent manner:
- Anti-Bribery and Corruption Policy
- Whistleblowing Policy
- Recruitment Policy
- Code of Conduct
These policies and an employee handbook are distributed to all employees, with training provided.
How we measure effectiveness
The implementation and effectiveness of the Wallacea’s anti-slavery approach and policies is reviewed annually by the senior management team and is supported by periodic reviews and risk assessments performed by Wallacea’s CEO.
Next steps
Wallacea is committed to continually addressing the potential risks of modern slavery and human rights abuses and will continue to take steps to review and, where appropriate, further improve its processes to ensure appropriate mitigation of any risks.
During the year ahead Wallacea will be paying particular focus on the following areas:
- Training
- Due diligence
- Risk assessment of supply chain
Approval
The statement has been reviewed and approved by Wallacea’s Board of Directors on 12/12/2023 and signed on its behalf by:
Paul Morgan
Chief Executive Officer
12/12/2023
