Modern Slavery Policy 


Introduction

Extra MSA Property (“The Group”) is committed to continuously improving its high standards to combat slavery and human trafficking in its business and supply chain, and in acting ethically and with integrity in its business relationships.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It constitutes The Groups slavery and human trafficking statement for the financial year ended 31 December 2018. It covers the activities of The Group and its wholly-owned subsidiaries.

Our organisation

The Group is a property investment group which owns and develops Motorway Service Area’s (“MSA’s”) in the UK.

Our supply chain

The Group uses a wide range of suppliers who supply goods for sale, provide services and support our operations.

Policies

The Group has a number of policies which aim to minimise the risk of modern slavery in our supply chain. These include:

  • Whistleblowing Policy which encourages staff to report any concerns including any related to modern slavery/trafficking and child and forced labour.

Risk Assessment

The Group considers the highest risk part of its supply chain is within the construction subcontractors.

The Group employ the vast majority of all operational site staff including night security guards, field, office and reactive maintenance staff. The Group has procedures in place designed to prevent human trafficking or slavery within our employee base. These include but are not limited to reference checks, checks on original right to work documents and checks that bank account details provided for the payment of salary match the name of the employee. Where discrepancies arise, further investigation is carried out to ensure the employee is not subject to modern slavery.

Our Next Steps

Over the coming year we aim to put a number of steps in place to ensure that our business and our supply chains are free from modern slavery. These are the steps we intend to take:

  • Review our supplier contracts to ensure that our suppliers must specifically declare modern slavery is absent from their business and supply chains as part of their contract with us.
  • Develop a supplier Code of Practice that we expect all of our suppliers to sign up to.
  • Develop a Working with Suppliers and Partners Policy which sets out internal requirements for buying goods and services.
  • Develop a Responsible Procurement Policy covering issues of human rights, child and forced labour and modern slavery, which all UK suppliers are required to comply with.
  • Develop our training to ensure all of those involved in purchasing goods and services are aware of the risks of modern slavery and are able to account for this in their dealings with suppliers.

Approval

This statement has been approved by the Executives of The Group.