Stelling Properties Group
Policy Statement and Aims
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery,
servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation
of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a
zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all
our business dealings and relationships and to implementing and enforcing effective systems and controls to
ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also 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 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 committed to ensuring that all employees receive fair pay in line with the UK National Minimum
Wage (NMW) and National Living Wage (NLW) legislation. This policy outlines our commitment to
compliance and fair treatment of all employees, including part-time, temporary, casual, and agency workers.
We will ensure that:
• All employees are paid at least the applicable National Minimum Wage or National Living Wage
rate, as set by the UK Government, based on their age and employment status.
• Review pay rates annually, or whenever the government updates the statutory rates, to ensure
ongoing compliance.
• Keep accurate payroll records to demonstrate compliance with wage legislation.
• Ensure that no deductions are made from wages that would reduce pay below the legal minimum,
except where permitted by law.
• Provide employees with clear payslips showing hours worked, pay rate, and total pay.
Other polices that should be read in conjunction with this policy are:
• Equality, Diversity & inclusion Policy
• Whistleblowing Policy
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. This policy does not form part of any employee’s contract of employment and we may amend it at any time.
Management Responsibility
The Board has overall responsibility for ensuring this policy complies with our legal and ethical obligations,
and that all those under our control comply with it. The Board has primary and day-to-day responsibility for
implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing
internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply
with this policy and are given adequate and regular training on it and the issue of modern slavery in supply
chains.
Employee Responsibility
You are invited to comment on this policy and suggest ways in which it might be improved. Comments,
suggestions and queries are encouraged and should be addressed to the Compliance Director.
You must ensure that you read, understand and comply with this policy. The prevention, detection and
reporting of modern slavery in any part of our business or supply chains is the responsibility of all those
working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a
breach of this policy. In particular:
• You must notify your manager as soon as possible if you believe or suspect that a conflict with
this policy has occurred or may occur in the future.
• You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of
our business or supply chains of any supplier tier at the earliest possible stage.
• If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify
your manager as soon as possible.
• If you are unsure about whether a particular act, the treatment of workers more generally, or their
working conditions within any tier of our supply chains constitutes any of the various forms of
modern slavery, raise it with your manager.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers from any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is, or may be, taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising concern. If you believe that you have suffered any such treatment, you should inform your manager or HR immediately.
Training and Communication
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.