MODERN SLAVERY ACT STATEMENT – FEBRUARY 2019



This is the modern slavery and human trafficking statement of Rightacres Property Co. Limited and all of its subsidiaries and UK Group companies (including Rightacres Property Group Limited, Central Quay One Limited and Destiny Living Limited (formerly known as Rightacres Property Group (Fusion 3) Limited)). This statement is made pursuant to the Modern Slavery Act 2015 (“The Act”) and has been adopted by all subsidiaries and group companies listed above as their respective slavery and human trafficking statement for the current financial year, ending 30 September 2019.

The principal activities of Rightacres Property Co. Limited include property development, property investment and property trading.

Our supply chain comes from many different areas. However, in our dealings with our suppliers, contractors and consultants, we strive to ensure that the highest ethical standards are achieved at all times.

We are committed to ensuring, as far as practically possible, that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure that slavery and human trafficking is not taking place anywhere in our supply chain or business. To ensure this, we regularly request confirmation of compliance with the Act by our main contractors and their sub-contractors and expect them to comply fully with the legislative requirements. We have always run our business with skilled managers to ensure optimum control of the work environment. Where possible, we build strong long-standing relationships with local suppliers and contractors and make clear our expectation of business behaviour (and the importance of compliance with the Act). We do not directly employ the people who work on our development sites, but we take very seriously the adherence to the provisions of the Act by our contractors and consultants.

We are a small employer (with fewer than 12 employees) and we have policies in place regarding employee conduct and welfare. These policies are reviewed and amended regularly to comply with our stance on forced labour, slavery and human trafficking.

In terms of employee recruitment, we have procedures in place to ensure that all employees are entitled to work in the UK at their own free-will and understand that they can cease their employment at any time under the terms of their employment contract. Employees are compensated with salary and benefits packages that meet or exceed the statutory minimum legal requirements. We also comply with the Working Time Directive, unless employees voluntarily chose to opt-out (within the limitation imposed by the Working Time Directive). Training is provided to relevant members of staff to ensure a high level of understanding of the risks of modern slavery and human trafficking. We expect all employees to report concerns and the Board of Directors is expected to act on them; the protection of whistle blowers is guaranteed.

The vast majority of our suppliers and contractors are based in the UK and, therefore, pose minimum risk in terms of non-compliance with the Act. Although we see our business as low risk in relation to the threat of slavery and human trafficking offences being committed, we are committed to carrying out compliance audits on a regular basis. We have zero tolerance to slavery and human trafficking and expect all those in our supply chain, contractors and consultants to comply with our values.

This statement has been considered, approved and adopted by the Board of Directors of all of the group companies and subsidiaries listed above for the current financial year, ending 30 September 2019.

Paul McCarthy

Chief Executive 14 February 2019