Modern Slavery & Human Trafficking Statement

Introduction

This statement sets out Elan Homes’ actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.  This statement relates to actions and activities during the financial year 1 November 2016 to 31 October 2017.

As part of the Construction Industry, the Company recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The Company is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Elan Homes Holdings Limited and its subsidiaries:

As a house-building business operating within the UK, the key areas of our operation which could be affected by slavery and human trafficking are our directly hired employees, agency workers working on our behalf, subcontractors operatives working on our sites and the workforce of our supply chain who supply materials to our business.  The steps that we take to mitigate risks in relation to each of these areas are as follows:-

Employees:

We verify that all employees have the right to work in the UK upon commencement of their employment.

We make all employees aware of their working hours, annual leave and absence entitlements and other employee benefits via the Company Handbook and Company Induction process.

Agency Workers:

We aim to only engage agency workers that are provided by suppliers on our Preferred Supplier List. We require all Preferred Suppler List suppliers to 

• ensure their agency workers have the right to work in the UK;

• confirm that they do not charge workers a work finding fee and 

• to have procedures in place to minimise the risk of recruiting forced or compulsory labour;

Suppliers and Subcontractors:

We will request that our suppliers and subcontractors take reasonable steps to ensure that their employees have the right to work in the UK;

We are contacting our supply chain to obtain, where required, copies of their Anti Slavery and Human Trafficking statements and policies and these will be audited annually to form part of our Quality Assurance systems.

We consider supplier and sub-contractors’ approaches to employee rights and any breaches of human rights related legislation during our selection process.

We want all suppliers and sub-contractors that purchase materials for use on our sites to consider the risk of modern slavery in their supply chain.

Whistle Blowing:

Our whistle blowing procedures allow any employee or third party to confidentially raise a concern.

This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. 

Breaches:

We will treat any breach of our Anti Slavery and Human Trafficking Policy very seriously.  For example, any employee who breaches the policy will face disciplinary action which could result in dismissal for misconduct or gross misconduct.

Any breach by a supplier to meet the standards of our Anti Slavery and Human Trafficking Policy may result in the termination of our relationship with them.

Any breaches reported will be investigated thoroughly.

Responsibility:

The Group Managing Director is responsible for the contents of this statements, which will be reviewed and updated as necessary on at least an annual basis.  Overall accountability for compliance rests with the Board of Directors.

John Kendrick

Group Managing Director