Modern Slavery Statement

Modern slavery encompasses slavery, human trafficking, forced labour and domestic servitude.

Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive

and force individuals into a life of abuse, servitude and inhumane treatment.

Placefirst Ltd. is committed to minimising the risk of modern-day slavery and human trafficking

within its business and from within its supply chains, including sub-contractors, and partners.

The Organisation upholds the spirit and intentions of the Modern Slavery Act 2015 and

understands the requirement of ongoing review of both internal practices in relation to its labour

force and supply chains.

This statement is made on behalf of Placefirst pursuant to section 54(1) of the Modern Slavery

Act 2015 (“the Act”) and constitutes our anti-slavery and human trafficking statement for the

financial year ending 31 December 2022.

Definitions

The Organisation considers that modern slavery encompasses:

• human trafficking

• forced work, through mental or physical threat

• being owned or controlled by an employer through mental or physical abuse of the threat

of abuse

• being dehumanised, treated as a commodity, or being bought or sold as property

• being physically constrained or to have restriction placed on freedom of movement.

Organisation Structure and Supply Chains

Placefirst is the parent company of a number of wholly owned subsidiaries which invest in, build,

and manage residential property in the UK.

• A link to the Organisation Executive Structure with key areas of responsibility. The

structure is designed to ensure compliance across the organisation.

• The organisation structure is designed to promote compliance, to ensure scrutiny and

minimise risk. Policy decisions are legally checked, impact assessed and sit outside the

respective service area.

• Placefirst have robust contracts that ensure our supply chain is scrutinised for compliance

and consequences of non-compliance are clear and actioned i.e. that commercial

relationships with suppliers, contractors and other business partners will not be entered

into (or terminated if existing)

• We ensure transparency within the Organisation, suppliers of goods and the larger supply

chain and services to the Organisation.

• Employment Agencies confirm they have done their appropriate checks and all checks

are passed in advance of temporary employment.

Policies in relation to slavery and human trafficking;

• Placefirst legally checks the following purpose to ensure they remain fit for purpose.

Procurement, Complaints, ESG, Recruitment, Code of Conduct, Whistleblowing, Equality

and Diversity and Disciplinary, Anti bribery & Corruption polices.

• The policies are present on the HR system for all colleagues to observed and included in

the initial induction meetings with new starters.

• Our colleagues have access to an employer support line, for support with whistleblowing.

Due Diligence Processes Include;

• Placefirst require a formal declaration from suppliers that they comply with the Modern

Slavery Act 2015

• Procurement questionnaires for potential suppliers.

Risk Assessment

• Development of new homes – construction workers and supply chain, including sites

managed under our in-house construction organisation Placefirst Construction.

• Procurement of repairs materials, parts, etc.

• Use of facilities management contractors

Risk Management

• We continue to raise awareness of modern slavery risks across the business by promoting

the National Crime Agency short video, and by delivering training to our Board and

employees. This training is delivered by webinars provided by legal advisors, e-learning

tools and inductions.

• We assess and reduce the risk in the business of modern slavery practices occurring by

checking the authenticity of papers proving a right to work in the UK, in advance of

contracts being issued.

• We plan to promote to staff the importance of raising immediately any concerns.

• We seek to protect staff who are ‘whistle blowers’ in respect of concerns they have about

modern slavery.

• Suppliers are asked for a statement against their compliance with the Modern Slavery Act

2015.

• We have a specialist procurement function that has primary responsibility for procuring

goods and services on a group-wide basis in accordance with the aforementioned

legislation and regulation. High value contracts require approval by the Board.

Some other measures that we have taken, or are in the process of taking, include;

• Review of our standard contract terms and introduction of a provision that requires

suppliers to comply with the Modern Slavery Act 2015.

• Review of our procurement policy and strategy.

Key Performance Indicators to measure steps being taken

• Management Indicators are set across the business. Modern Slavery forms part of

discussion related to key policy / decision makers.

• The organisation has a performance management framework that seeks to improve

performance.

Conclusion

We are not aware of any modern slavery or human trafficking incidents have occurred within

Placefirst or our supply chain within 2023, but will continue to act vigilantly and in line with the

Modern Slavery Act throughout 2024..

We will continue to require compliance with our procurement process which includes measures

to ensure that our obligations under the Act are passed through our supply chain.

Publicising on the website

A link is placed on a prominent place on our homepage for published statements. This statement

replaces the previous year’s statement.

Board Approval

Board approval has been given by the Placefirst Board on 24th April 2024 . Going forward future statements

will be reviewed and publicised by March of each year.

CEO Signature

Date: 24th April 2024