Modern Slavery Act Statement

GAZELEY MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR THE FINANCIAL YEAR ENDED 31 DECEMBER 2016

This statement is made by Gazeley Holdings UK Limited (and each of its direct and indirect subsidiaries), (“Gazeley”) registered at Companies House with company registration number 06601780 (we, us, our or the Company) pursuant to section 54, Part 5 of the Modern Slavery Act 2015 ( the “Act”).  It constitutes our slavery and human trafficking statement for the financial year ended 31 December 2016 and sets out the steps taken to ensure that slavery or human trafficking did not take place in our business and supply chain during this financial year.

Gazeley is an investor and developer of logistics real estate in Europe. Gazeley has approximately 50 employees in in Europe.

GAZELEY BUSINESS AND SUPPLY CHAIN

Gazeley’s business is within the real estate sector and our supply chain particularly for our development projects involves high volumes of construction.  Our supply chain often involves several entities or projects performed by a prime contractor with a series of sub-contractors. We can only exercise control over our relationship with our contractual counterparty; those persons who contract with that counterparty will be performing services for the counterparty and not for other persons in the contractual chain.

The principal way in which we approach modern slavery risks in our supply chain is by way of the procedures as set out in our Construction  Procurement Policy, our Third Party Diligence Policy and our Code of Business Conduct and Ethics (the “Code”) (together the “Policies”). The Policies include our seeking to conduct our business in a manner that is free from slavery and human trafficking.

We have a commitment to conduct our business and all our relationships based on integrity.  This commitment is contained in our Code.

During this financial year we started to:

  • Update our Policies to reflect our commitment to:
    • implementing and enforcing effective systems and controls designed to eradicate modern slavery in our business and supply chains;
    • being transparent in doing so through our disclosure obligations under the Act.;
  • Use risk assessments;
    • Our efforts to prevent modern slavery are designed to be proportionate to the modern slavery risks we face, recognising that it can vary according to the jurisdictions, sectors, suppliers, the amount of control we have over our supply chain and other governance factors. Risk assessments are, therefore, integral to our attempts to eradicate modern slavery in our business and supply chains.  In particular, we seek to ensure that modern slavery risk is managed as close to its source as possible, and by the management teams that have the most knowledge and expertise in the business or risk area. Modern slavery risks vary based on the characteristics of each business. The specific manner and methodologies by which these risks are addressed and mitigated vary based upon, among other things, the nature of the risks and of the assets and operations to which they apply, the geographic location of the assets, the economic, political and regulatory environment, and our assessment of the benefits to be derived from such mitigation strategies.
    • We have identified that there is a risk of modern slavery and human trafficking within our construction supply chain, however given our commitment to our Policies, we consider the residual risk to be low and we continue to monitor the risks on an on-going basis.
    • While no practices and procedures are capable of identifying and preventing all modern slavery, our risk based approach is designed to enable efforts to be focussed where they are most needed and can most help eradicate modern slavery.
  • make available training to our staff on modern slavery risks;
  • put in place a due diligence protocol that includes anti-slavery considerations embedded within our Third Party Due Diligence Policy, which applies when engaging or renewing third party suppliers; and
  • encourage staff, our suppliers and business partners and anyone else to whom our Policies apply to report any concerns about modern slavery related to its businesses and direct supply chains in accordance with our Policies.

TRANSITIONAL ARRANGEMENTS

We have updated our Policies demonstrating our commitment to implement transitional steps to try to give effect to that of a full and detailed Modern Slavery and Human Trafficking Policy.

EFFECTIVENESS

Based on the above, we consider that our policies and procedures are transitioning towards a reasonable, but not absolute, level of assurance of effectiveness in eradicating modern slavery and human trafficking in our business and supply chain, recognising that this is the first financial year for which we have produced this statement.

Approved by the Board of Directors of Gazeley Holdings UK Limited and signed by Patrick McGillycuddy, Director of Gazeley Holdings UK Limited on behalf of Gazeley Holdings UK Limited on 22 September 2017.

Patrick McGillycuddy
CEO of Gazeley Europe and
Director of Gazeley Holdings UK Limited

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