Modern Slavery and Human Trafficking Statement

Company Policy Statement

This statement is made by Highwood Group Limited and has been approved by the Board in accordance with Section 54 of the Modern Slavery Act 2015 and relates to actions and activities during the financial year 1st July 2023 to 30th June 2024.

As part of the Construction Industry, we recognise our responsibility to take a robust approach to slavery and human trafficking. We are wholly committed to preventing slavery and human trafficking in all our business activities and to ensuring that our supply chain is free from slavery and human trafficking.

About Highwood Group

Established in 1987 we have delivered an extensive portfolio of projects across the south coast of England that includes house building, care home construction and land acquisition and planning. Situated in Romsey, Hampshire, our Head Office is home to our central and support teams and each site we manage houses our onsite project teams, specific to that build.

The Highwood Group complies with all relevant employment law legislation and we expect our suppliers and sub-contractors to do the same.

Policy

Our policy reflects a commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere within our business or that of our partners or supply chains.

Procedures

Our key risk is in our supply chain and we are conscious that the industry we work in can include areas of high risk, with various roles that can provide opportunities for exploitation. We are committed to ensuring that there is no slavery or human trafficking in our supply chains, and it is our policy to implement effective and robust controls to ensure this is not taking place.

All new suppliers undertake a level of due diligence before they are accepted as a supplier, including a comprehensive supplier questionnaire which includes confirmatory statements around a commitment to ensuring compliance with the modern slavery act.

Where appropriate or we feel there is an increased risk, we ask sub-contractors and suppliers to provide to us with their current Modern Slavery Statement.

We have updated our terms and conditions with current suppliers such that we are requesting a commitment for them to adhere to the modern slavery act and that they, in course, also hold their suppliers to account over modern slavery.

Supply Chain

Our supply chain involves local and national companies. Materials and goods that make up our builds may include raw materials from, or may be assembled in, countries that are at a high risk of slavery and/or human trafficking. Our procurement team are responsible for the management of this area and work closely with suppliers to make sure they are aware of the potential for slavery and human trafficking.

The processes stated also include provisions to ensure that the expectations and obligations are passed down the supply chain and not restricted to the immediate link in the chain that is most visible. We will report any evidence or suspicion of cases or hidden third party labour exploitation to the Gang masters and Labour Abuse Authority immediately. Failure by managers and leaders of the company, third party labour providers or organisations in the labour supply chain to act upon concerns of worker maltreatment, coercion or harassment will be regarded as potential gross misconduct and will be managed accordingly through the relevant disciplinary process.

Whistle-blowing

We encourage all our workers, customers and business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistle-blowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Information is available on notice boards on all sites for suppliers and sub-contractors and through our HR portal for all employees. Our full whistle-blowing policy is available in our Employee Handbook and upon request. Workers are also able to report concerns via Protect’s confidential helpline, 020 3117 2520.

Training

All our staff complete an e-learning training session on Modern Slavery and Human Trafficking and must complete a test at the end, achieving a minimum of 80%. This testing will be forms part of the induction for every new starter and we ask that everyone repeats it every two years. There are also adhoc reminders via email and team meetings regarding what to look out for and how to recognise modern slavery and human trafficking in the working environment.

Further Steps

We will continue to review all our processes and training and make any legal and necessary changes as required.

Authorised for issue by:

Mark Baskerville

Chief Executive Officer, Highwood Group

1^st July 2023