The Modern Slavery Act 2015 places an obligation on UK businesses with a turnover of over £36 million to produce a modern slavery statement. Slavery and Human Trafficking remains a hidden blight on our global society. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. Staff are expected to report concerns and management are expected to act upon them.
L&Q Estates are developers and promoters of residential, commercial and mixed-use real estate developments in most geographical areas of the UK.
We are dedicated to providing our employees with a positive working environment which complies or exceeds the requirements of all applicable legislation including human rights, anti-discrimination and fundamental rights at work.
L&Q Estates (and the legal entities set out in Appendix A hereto) are wholly owned by L&Q Housing Trust but operate as a separate 'arms-length' business with its head office in Warwick.
We have absolutely zero tolerance to slavery and human trafficking and are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. It is our policy to act ethically and with integrity in all our business relationships and to implement and enforce effective systems and controls to help eradicate slavery and human trafficking.
We do not employ many people directly or indirectly.
Our directly employed staff comprise approximately forty-three people. We continue to consider the risk of modern slavery and human trafficking occurring within our directly employed workforce to be very low given its size, skills and professional nature. Our staff are all paid above the UK living wage and all appropriate ID checks are made before employment commences.
Our supply chain is limited. For our promotion of development, we employ external professionals and our assessment of the risk of slavery and human trafficking in our external professional supply chain is that it is considered extremely low risk.
We do service some of the land we control and in procuring such servicing of land, to bring development sites forward for sale, we employ principally major civil engineering contractors.
It is our assessment that the risk of slavery and human trafficking in this part of the supply chain is also low. However, notwithstanding our assessment, we are engaging with such external contractors to establish that they have appropriate policies in place, as they will themselves employ sub-contractors.
On an analysis of the L&Q Estates business, looking for areas of risk, the only other areas where it is considered there may be risk of slavery and human trafficking relates to the provision of external facilities services for its offices. Again, the risk of slavery and human trafficking is considered to be low. However, as with external contractors, we have expressly made enquiries and will continue to engage with external suppliers of facilities services for our office to establish that they have appropriate policies in place.
Notwithstanding the difficulties caused by the Corona Virus Pandemic we have taken the following steps in the last year:
• Required major new suppliers to declare that they are not involved in slavery or human trafficking and have not been subject to any investigation in connection with any offence involving slavery or human trafficking
• Update our formal tender documentation to notify all suppliers that we expect them to comply with the Modern Slavery Act.
• Undertaken a paper audit of all identified suppliers to seek to ensure that
- those of our suppliers and external professionals who should have Modern Slavery Statements had published statements and
- to seek to identify those very few suppliers or professionals who may be considered high risk
• Establish a whistleblowing policy for all staff.
Notwithstanding our stated view of risk in our supply chains, we will continue to work to the highest professional standards and shall be vigilant in our efforts to identify acts of modern slavery within our business and supply chains. We will aim to:
• Ensure that we have incorporated provisions in our consultant appointments, contractor appointments and external facility provider appointments requiring our suppliers to take appropriate steps to ensure that there is no slavery or human trafficking in their supply chains
• Ensure that our induction protocol for New Starters will include training in Modern Slavery
• Form a Compliance Committee
• Work towards having an approved list of contractors and suppliers especially in any areas considered high risk
L&Q Estates Limited Principal Trading Company 2019 plus
Gallagher Estates Holdings Limited Intermediate Holding company and principal trading company to 2019
Portobello Developments 2002 Limited Property development
Wixams First Limited Property development
Gallagher Estates NR Limited Property development
Drayton Stratford Limited Property development
West Longstanton Limited Small company property development
Gallagher Homes Limited Property development
Gallagher Longstanton Limited Property development
Gallagher Llanwern Limited Property development
Gallagher Projects Limited Procurement and delivery of infrastructure and other construction activities
Gallagher Elstow Limited Property development
Gallagher Bridgend Limited Former property development entity
Gallagher Poole Limited Property development
Gallagher Estates Land Limited Dormant
J.J. Gallagher Construction Limited Dormant
Redlawn Land Limited Property development
We will assess any evidence of non-compliance and will take appropriate remedial action. We will only trade with those who comply with this statement and the terms of our appointments or those who are taking verifiable steps towards compliance.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year 2021/2022.
This statement will be reviewed and updated on an annual basis and is approved by the L&Q Estates Board. It applies to all companies and organisations within the L&Q Estates Group.
Approved by the L&Q Estates Board 21st June 2021
Group Managing Director, L&Q Estates Ltd
21st June 2021