- Liberty Living
- Modern Slavery Statement
Modern Slavery & Human Trafficking Statement
The Liberty Living Group (defined in the next section) is committed to doing business in a responsible way, and through our activities, to earning a reputation for quality, integrity and social responsibility within the purpose built student accommodation (PBSA) sector. Aligned with this objective is our wholehearted and active support for the aims of the UK Modern Slavery Act 2015.
Our commitment is to ensure that slavery, human trafficking, child labour (or any abuse of human rights) have no place in or around our organisation. We recognise the importance of the role we can play in preventing such abuses within our spheres of influence, to create a culture of awareness and transparency and actively engage in the eradication of modern day slavery.
In publishing this statement, we are pleased to outline the steps that the Liberty Living Group has taken (and is going to take) to meet these objectives.
For the purposes of this statement, Liberty Living Group (or the Group) means the group of companies comprising the Liberty Living group of bodies corporate during the relevant period (being Liberty Living Investments Limited; Liberty Living Investments GP1 Limited; Liberty Living Investments GP2 Limited; Liberty Living Investments GP3 Limited; and Liberty Living Investments II Limited, together with their subsidiaries and subsidiary undertakings).
Liberty Living Limited acts as property manager to the Group. In its capacity as property manager, Liberty Living Limited is the entity responsible for making this statement on behalf of the whole Group.
The Liberty Living Group owns and operates a geographically diverse portfolio of high quality, modern and well-maintained properties. As at 31 August 2017, the portfolio consisted of 23,686 rooms across 51 residences in 19 major university towns and cities across the UK, plus an asset in each of Germany and Spain.
Our employees help us operate our properties and provide accommodation-related support and services to our students. As at 31 August 2017:
• The UK entities in the Group employed 387 employees and contracted with 82 casual workers, all of whom were UK based.
• Our Spanish operations employed 76 employees and contracted with 26 casual workers based at one residence in Valencia.
• Our German operations employed 4 staff in Bremen.
About our supply chains
Our supply chains relate to our real estate holdings and our PBSA-operational business. These supply chains encompass personnel, as well as goods and services to support our activities. As a Group we source a wide range of goods and services, and our suppliers cover a range of manufacturers, construction companies, material and product suppliers and professional and other third party providers. Most of our supply chain is based in the UK.
Assessment of risk
The Liberty Living Group opposes all forms of slavery and human trafficking, and we are committed to taking steps to ensure that they do not occur in our business or our supply chains. Through a cross-functional working group, we commenced a process of reviewing our business and supply chains to identify and assess the risk of slavery and human trafficking in our business, as well as the measures already in place to address such risks, and any additional measures that may be warranted in light of the review.
While cognisant and vigilant that we could be at risk of slavery or human trafficking within our own business, we believe that there is a greater risk of slavery or human trafficking occurring within our supply chains. Accordingly, we have identified the following areas as being areas that potentially carry a greater risk of modern slavery:
• Construction-related activities.
• Cleaning services.
• Security services.
• Suppliers sourcing from identified high-risk countries.
Actions taken and our intentions
A number of policies designed to reflect our commitment to responsible, sustainable and ethical business are already in place in our business. These include, but are not limited to:
• Employment and labour practices and policies that include matters relating to diversity and equal opportunities.
• Gifts, Hospitality and Anti-Bribery.
Our specific modern slavery policy will be fully rolled out across our wider business in order to enhance the existing policy framework within the Group. As part of our broader commitment to identify and mitigate risk in our supply chain the Group has also:
1. Continued to conduct robust in-house checks on our employees and directly contracted workers: The Liberty Living Group conducts robust in-house checks on all our employees and directly contracted workers to ensure that they have the legal right to work in the UK. The majority of our temporary summer workforces are recruited directly to ensure fair pay and practices and we only use specified, reputable employment agencies for additional temporary staff to work alongside our existing teams. We always verify and agree the worker payment rates and review the employment practices of any new agency we use before accepting workers from that agency.
From January 2018, we intend to only work with recruiters who can provide us with acceptable details of their policy and/or procedures relating to Modern Slavery and Human Trafficking.
2. Recruited a new Procurement Manager and Legal Director into the business: Along with the rest of the Executive Management Team, these new hires will further enhance the Group's ability to strategically mitigate the risk of modern slavery in our supply chains, including by:
• Conducting a further "deeper dive" risk assessment in relation to those areas of higher risk identified above in the "Assessment of risk" section, to enable the Group to focus on mitigating these risks going forward.
• Developing and adopting a supplier code of conduct.
• Developing and utilising UK supplier questionnaire to include questions to help us understand a potential supplier's commitment to ensuring that no modern slavery is taking place in its business and own supply chains.
• Developing a process with the aim of ensuring that appropriate contractual provisions are incorporated into new supplier contracts, leases, our agreements with Educational Institutions and other commercial agreements and renewals of such existing contracts, which require a supplier to take steps to ensure that slavery and human trafficking are not taking place in its business or in its supply chains.
The Group is also intending to roll out measures designed to ensure that its employees are trained to identify possible incidences of slavery and human trafficking, and to understand the implications of the Modern Slavery Act for our organisation. For example, we are intending to develop a mandatory online training programme for all our staff, covering the topic of modern slavery, the requirements of the Modern Slavery Act and its implications for the Group's business. We are also working on the development of specific training programmes for groups of our staff, such as the teams involved in procurement, property maintenance and human resources, in relation to the issues relevant to their areas of expertise.
Status of statement
This statement is made in accordance with section 54 of the Modern Slavery Act 2015 and covers the Group's financial year ending 31 August 2017. The statement covers the Group and its subsidiaries, including those UK companies with a turnover greater than £36m.
Chief Executive Officer
For and on behalf of Liberty Living Limited (in its capacity as property manager of the Group).
Date: 7 November 2017