MODERN SLAVERY POLICY

This policy supports our commitment to limiting the risk of modern slavery occurring

within our own business or infiltrating our supply chains or any other business relationship.

The policy applies to all persons working for or on our behalf in any capacity. Including but not limited to employees, directors, agency workers, contractors, consultants and any other third-party representative.

We expect all who have a business relationship with the company to familiarise themselves with this policy and to act in a way that is consistent with its values.  We will only do business with organisations who fully comply with this policy.

This policy will be used to inform any statement on slavery and human trafficking that we are required to produce further to the transparency in supply chain requirements of Section 54 of the Modern Slavery Act 2015 (MSA).

Modern slavery is a complex and multi-faceted issue that manifests itself in many different forms. This includes, but is not limited to, four key criminal activities:

• Slavery: where ownership is exercised over an individual.
• Servitude: involves the obligation to provide service imposed by coercion.
• Forced and compulsory labour: all work or service, not voluntarily performed, which is obtained from an individual under the threat of force or penalty.
• Human trafficking: involves arranging or facilitating the travel of another with a view to exploiting them.

In order to tackle modern slavery, we must remain vigilant to the risks that are associated with conducting business in the 21^st Century.

We have identified that our biggest risk in terms of outsourced activities relates to the contractors employed to work at our developments. In order to ensure strict compliance with the Modern Slavery Act, we will put in place systems that seek to address the issues associated with the aforementioned issue and the continuing risk our business faces from modern slavery in its wider supply chain. This includes useful information on spotting the signs of modern slavery and labour exploitation such as restricted freedom; behaviour; working conditions; accommodation; finances and appearance.

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

The Management Board has overall responsibility for ensuring this policy complies with our

legal and ethical obligations. Additionally, all those under our control must comply with the policy whilst maintaining a certain level of day-to-day responsibility for the following:

• implementing this policy,
• monitoring its use and effectiveness,
• dealing with any queries about it,
• auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Status of this policy

This Anti-slavery policy will be reviewed by the Management Board on a regular basis.  This policy does not give contractual rights to company employees and we reserve the right to alter any of its terms at any time.  We will notify applicable parties of any changes which may affect them.