Modern Slavery Statement

INTRODUCTION

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

We are proud of the steps we are taking to combat slavery and human trafficking and are committed to reviewing our practices on an ongoing basis to improve our practices and eliminate risks.

ORGANISATION'S STRUCTURE

Bewley Homes was founded in 1991 and focuses on building quality homes in highly desirable locations.

Bewley Homes Plc is a Public Limited Company and our ultimate parent company is Bewley Group Limited. Bewley Homes Plc is the only trading entity with a turnover in excess of £36 million. We produce around 375 homes each year and as of the date of this statement have 120 directly employed employees. Our head office is based at Inhurst House, Brimpton Road, Baughurst, Hampshire, RG26 5JJ and we only operate within the United Kingdom.

We had an annual turnover of £131 million for our financial year ending 30 September 2018.

OUR SUPPLY CHAINS

Our business requires us to identify and acquire developable land, obtain planning permission and plan and build quality homes. Our supply chains therefore principally involve the supply of suitable labour and subcontractors and the purchasing of housebuilding materials.

As part of our initiative to identify and mitigate risk we have carried out a review of our supply chains to identify and assess any potential risks for slavery and human trafficking. We have then taken the steps outlined below and in our Anti-Slavery Policy to mitigate the areas of risk identified.

Employees

We comply with, as a minimum, all employment law requirements in the United Kingdom and honour important rights such as national minimum wage and paid holiday requirements. We also ensure that all of our employees have the right to work in the UK.

Agency workers and subcontractors

We are committed to ensuring that any employment agencies which supply us with workers and any sub-contractors are advised of our Anti-Slavery Policy and confirm that they will comply with its terms or show a similar commitment to eliminating slavery and human trafficking in their business and own supply chain.

We expect all employment agencies to comply with their own obligations under UK law in respect of their business, including all agency regulations and employment laws.

Material suppliers

We are aware that the fact that some of the materials we purchase (such as timber) are ultimately sourced from countries where there is a greater risk of modern slavery or human trafficking. We are accordingly committed to ensuring that all suppliers are advised of our Anti-Slavery Policy and confirm that they will comply with its terms or show a similar commitment to eliminating slavery and human trafficking in their business and own supply chain.

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

We are committed to ensuring as far as we are able that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Our Whistleblowing Policy also ensures that any concerns that our employees, contractors or suppliers may have can be raised without fear of retribution or being subjected to a detriment as a result.

SUPPLIER ADHERENCE TO OUR VALUES

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we are requiring all of our suppliers, whether identified as high or low risk, to confirm that they will comply with our Anti-Slavery Policy.

If they are unable to commit to complying with our own Anti-Slavery Policy, we will expect them to show and evidence a similar or greater commitment to eliminating the risk of modern slavery in their business and their own supply chain.

If they fail to confirm that they will comply with our Anti-Slavery Policy and are unable to demonstrate, to our satisfaction, a similar or greater commitment to eliminating modern slavery, then those suppliers will not receive any further payments from ourselves and be removed from our approved supplier list.

We are implementing these changes into our supplier system and we aim by September 2019 to be able to have confirmation from all of our suppliers of their compliance with our policy.

TRAINING

The board of directors has had training on the risks of modern slavery and human trafficking in our supply chains and our business. All existing employees have been provided with a copy of our Anti-Slavery Policy and invited to raise any questions or concerns that they may have.

Our Anti-Slavery Policy will shortly be incorporated into our employee Policy and Procedures Manual. All new employees will be advised of the importance of our policy as part of their induction and will be expected to sign that they have read and understood the Policy and Procedures Manual, including our commitment to eliminating modern slavery.

We will be reviewing over the coming year the necessity for wider training to all or selected employees.

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING

We are committed to ensuring that we have been effective in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains. Key Performance Indicators will develop over time, but we are currently focusing on ensuring by September 2019 that all of our suppliers have committed to comply with our policy or the standards it requires.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Bewley group's slavery and human trafficking statement for the financial year ending September 2019. This statement was approved by the board on December 17th 2018.

Signed for, and on behalf of, the board

Terence Bacon
Finance Director
Bewley Homes Plc