This statement is made in accordance with section 54 of the Modern Slavery Act 2015 and constitutes the Urbanest UK anti-slavery and human trafficking statement for the financial year ended 31st December 2017. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

We are committed to improving our practices to combat slavery and human trafficking.

Organisational structure

Urbanest UK is a student accommodation developer and operator. We have 5 operational properties all based in central London. In addition we have a number of properties in our development pipeline which are due to become operational in a phased manner over the next few years.

Our supply chain

The Urbanest UK supply chain can be broken down in to two broad categories. The first category being all materials and services purchased to develop our sites, this category consists of professional services (e.g. lawyers, architects, planning consultants, quantity surveyors) and construction services (e.g. main build contract to construct a student accommodation building). The second category being building management services, this consists of all the services required to operate and maintain our portfolio of buildings. This includes utilities, planned and unplanned maintenance, cleaning, security and lifecycle costs.

Policy

Urbanest UK will not tolerate any slavery or human trafficking within any part of our business or supply chain. All suspected infringements of this policy must be reported to a senior member of staff within the business and will be investigated robustly under the supervision of an executive level staff member. In addition Urbanest UK has a whistle blowing policy and process where concerns can be raised in a number of ways designed to encourage staff members to come forward with suspected wrongdoing and ensuring appropriate escalation paths are followed.

Risk assessment

Urbanest UK considers the highest risk part of its supply chain is within the construction subcontractors. Urbanest employ the vast majority of all operational site staff including night security guards, front desk staff and reactive maintenance staff. Urbanest UK has procedures in place designed to prevent human trafficking or slavery within our employee base. These include but are not limited to reference checks, checks on original right to work documents and checks that bank account details provided for the payment of salary match the name of the employee. Where discrepancies arise further investigation is carried out to ensure the employee is not subject to modern slavery.

Due diligence

Each of our building construction programmes has a single main contractor. This main contractor then sub contracts out work packages to various sub-contractors. Our main contractor conducts significant due diligence checks requiring all sub-contractors to:

  • Provide a copy of their anti-slavery and trafficking policies and procedures
  • Provide schedules of the % of products / materials by value sourced / manufactured / from high risk countries of origin as defined by the Global Slavery Index 2016 (split by direct and via sub-contractors of sub-contractors)
  • Provide evidence that the sub-contractor conducts annual / regular supply chain audits, either directly or through third party auditors to monitor performance, including:
    • Summary of audits or other activity undertaken to assesses labour standards in supply chains operating in high risk countries of origin.
    • Evidence confirming audits have been undertaken
    • Evidence confirming action is taken to address issues highlighted at audit.
  • Provide copies of template audits that detail the areas covered below
    • Compliance with all applicable laws, statutes, regulations and codes including but not limited to the, United Nations Global Compact and the International Labour Organization, International Labour Standards;
    • All employees afforded the freedom to choose to work for the sub-contractor (employees should be free to leave after reasonable notice is served).
    • Demonstrate a commitment to equality of opportunity for individuals and groups enabling them to live their lives free from discrimination and oppression;
    • Impose working hours on your staff which are compliant with national laws or industry standards;
    • Under no circumstances abuse or intimidate, in any fashion, employees and have appropriate disciplinary, grievance and appeal procedures in place;
    • Take appropriate measures to ensure the health and safety of their workforce and the wider public;
    • Offer wages and benefits that at least meet relevant industry benchmarks or national legal standards.

Training

Urbanest will be developing and rolling out an in house training program for all staff using guidance provided by the Gangmasters and Labour Abuse Authority.