Wain Group Limited is the parent company of Wain Estates Limited. Pursuant to section 54 of the Modern Slavery Act 2015, this statement constitutes the Modern Slavery Statement of Wain Group Limited and other Wain Estates companies as specified below ("Wain Estates"), for the financial year ending 30 September 2023.
The Modern Slavery Act 2015 creates offences in respect of slavery, servitude, forced or compulsory labour and human trafficking ("Modern Slavery"). Wain Estates is committed to combatting all such forms of Modern Slavery.
ABOUT WAIN ESTATES
Wain Estates is a property development, regeneration and strategic land company.
WAIN ESTATES SUPPLY CHAINS
Wain Estates is developing a Supplier Code of Conduct which sets out the minimum standards suppliers need to achieve with respect to areas such as labour and employment rights, health & Safety, ethics, social responsibility and the environment. The ability of organisations to comply with the Supplier Code of Conduct is a pre requisite to appointment for any Works or supply of materials.
Wain Estates usually employ a main contractor who would organise significant supplies including groundworks, steel, cladding and other building supplies. They would do so in accordance with the Wain Estates Supplier Code of Conduct.
In addition to the supplies and services procured in relation to the development of sites, Wain Estates relies on office supplies and facilities supplies to its premises in Warrington.
Whilst the Wain Estates projects are UK based and the number of suppliers used by the group is limited, Wain Estates recognises that Modern Slavery is not a risk that is restricted to construction projects overseas and that supply chains extend globally.
POLICIES AND PROCEDURES
The policies and procedures that Wain Estates has to combat Modern Slavery in its business are set out below.
Anti-Slavery and Human Trafficking Policy
Wain Estates is in the process of updating its suite of compliance policies and procedures and a part of that process will involve the introduction of an Anti-Slavery and Human Trafficking Policy. The policy will confirm Wain Estates' commitment to combatting all forms of Modern Slavery, require adherence by employees and suppliers and refer to the consequences of a breach.
Contractual controls
Wain Estates’ contractual terms contain a number of requirements which are relevant to reducing Modern Slavery risk. These include the requirement on contractors to obtain Wain Estates' consent prior to subcontracting, which allows due diligence to be carried out, and also the reservation of audit rights in respect of employment records of contractors. Wain Estates is in the process of reviewing those contractual provisions to increase protections in respect of Modern Slavery and expects to introduce revised standard terms shortly.
Due diligence of sub-contractors
Wain Estates conducts due diligence in respect of sub-contractors including checks of corporate and tax records and also to confirm that the sub-contractor maintains adequate policies and procedures in respect of health and safety. These compliance checks give Wain Estates a level of comfort in respect of the standing of the suppliers it works with. Wain Estates is currently considering introducing further checks and diligence in respect of its supplier base relevant to Modern Slavery risk.
Third party review
Wain Estates has engaged an external adviser to assist the group with assessing Modern Slavery risk and to further enhance Wain Estates' policies and procedures.
APPROVAL
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 for the financial year ending 30 September 2023 and has been approved by the board of Directors of the following Wain Estates companies.
Wain Estates Limited
Wain Estates (Property) Limited
Wain Estates (Carrington) Limited
Wain Estates (Land) Limited
Carrington Business Park Limited
Swinton Park Golf & Country Club 2017 Limited