Modern slavery

This statement is made in line with section 54(1) of the Modern Slavery Act 2015 and sets out Audley Group’s actions to understand all potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our own business and supply chains.

As part of the property, hospitality and care sectors, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking throughout our entire business. We are absolutely committed to preventing slavery and human trafficking in our business activities, and to ensure that our supply chains are free from slavery and human trafficking.

Organisational structure

This statement covers the activities of Audley Group Limited and all subsidiary companies. The Audley Group builds and operates retirement villages and operates care branches throughout the UK. We buy land, secure detailed planning consent and then build, sell and manage the high-quality retirement villages that we create. An important part of our operations once a village is created is to establish a domiciliary care business through which we provide care to our owners and to the neighbouring public.

The Audley Group currently directly operates within the UK only. We directly employed 818 people in the period ending 31 December 2020 as well as contracting with agency and subcontractor companies. Our revenue for the period was £71,579,000 (unaudited).

Supply chains

We require all our suppliers to confirm that they comply with the requirements of the Modern Slavery Act 2015.

Our supply chain is principally UK based. With international supply chains, our point of contact is with a UK company or branch and we require these entities to have suitable anti-slavery and human trafficking policies and processes. We expect each entity in the supply chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the supply chain, ultimately to the primary source of production.

We do not directly employ the workforce that constructs our villages, but indirectly engage them through our construction contractors. We use reputable, established contractors and carry out due diligence before engaging them to ensure they share the Audley Group ethics and values. We use a small number of suppliers in the construction process and this allows us to understand their own policies and procedures about modern slavery and human trafficking. This knowledge minimises the risks of us, through our contractors, having any involvement in modern slavery and human trafficking.

The hospitality and care sectors may also use casual and temporary workers. We directly employ our village team members and carers. The organisation does operate a bank contract to provide a mobile workforce, with regular reviews to ensure workers are active. We carry out detailed checks on all our employees, including enhanced DBS checks prior to commencement of permanent employment. Where temporary cover is occasionally used our policy is to use reputable firms that carry out right-to-work checks.

Responsibility for our anti-slavery initiatives including policies, risk assessments, investigations/due diligence and training ultimately lies with the Board of Directors.

Related policies

The Audley Group operates the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

Whistleblowing Policy: We encourage all our employees, workers, customers and other business partners to report any concerns related to our direct activities or supply chains. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can contact an external and anonymous 24-hour helpline.

Anti-bribery policy: Our policy confirms Audley’s zero tolerance of bribery and corruption and extends to all business dealings and transactions. All employees, officers, agents or consultants or any persons or companies acting for Audley or on our behalf are expected to adhere to this policy.

Employee Code of Conduct: Our code makes clear to employees the actions and behaviour expected of them when representing Audley. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.

Health and Safety Policy: Our policy on health and safety aims to develop a culture that is committed to the prevention of ill health and injuries to our employees and others that may be affected by our operations.

Employee Handbook: Our employee handbook provides information to all colleagues on their statutory rights, inclusive of sick pay, holiday pay and other benefits that they may be entitled to by their employment.

Modern Slavery & Human Trafficking Policy: Our policy aims to make clear our commitment to act ethically and with integrity in all our business dealings and relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains.

Due diligence

The Audley Group undertakes due diligence when considering taking on new suppliers, and regularly reviews our existing suppliers. The due diligence and reviews include:

• evaluating the modern slavery and human trafficking risks of each new supplier;
• Financial Status and Directorship checks;
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping; and
• creating an annual risk profile for each supplier.

Steps taken

We have undertaken the following activities to ensure that we are compliant with UK legislation:

• written to all suppliers asking them to confirm to us that there is no modern slavery or human trafficking in their supply chains or business and that they have adequate systems in place to identify, assess, monitor and mitigate potential risk areas in their business and supply chains and to protect whistleblowers;
• widened the scope of our whistleblowing policy to specifically include reporting on modern slavery and human trafficking;
• introduced further training on health and safety for all employees;
• developed a formal CSR policy including a clear objective that we will seek to ensure modern slavery is not taking place within our business or supply chains;
• developed a modern slavery policy;
• introduced training on modern slavery and human trafficking for all employees;
• in the event of any suppliers’ turnover being in excess of £36M, their Modern Slavery and Human Trafficking Statement must be updated annually and supplied to ourselves to confirm that there is no modern slavery or human trafficking in their supply chains or business, and that they have adequate systems in place to identify, assess, monitor and mitigate potential risk areas in their business and supply chains to protect whistleblowers; and
• for suppliers whose turnover is less than £36M at point of setting up the supplier relationship we gain confirmation as part of our due diligence that there are no modern slavery or human trafficking in their supply chain operation.

Future steps

It is important that our policies and procedures relating to the prevention of modern slavery and human trafficking evolve in line with best practice and changing circumstances. To that end we will be taking the following steps to ensure we are compliant with UK legislation:

• continue to monitor all suppliers to ensure that there is no modern slavery or human trafficking in their supply chains or business, and that they have adequate systems in place to identify, assess, monitor and mitigate potential risk areas in their business and supply chains and to protect whistleblowers;
• monitor training compliance rates to ensure that employees understand their responsibility in line with modern slavery and human trafficking; and
• write to all suppliers asking them to reconfirm to us annually that there is no modern slavery or human trafficking in their supply chains or business and that they have adequate systems in place to identify, assess, monitor and mitigate potential risk areas in their business and supply chains and to protect whistleblowers.

Board approval

This statement has been approved by the Board of Directors, who will review and update it annually, and signed on its behalf by:

Nick Sanderson
Chief Executive Officer