Modern Slavery

Clan (Regent Property) LLP ("LLP") Modern Slavery and Human Trafficking Statement for financial year ended 31 March 2022

1. Overview
   1. This statement is made under s54 Modern Slavery Act 2015 in respect of the financial year ended 31 March 2022. The LLP has a zero-tolerance approach towards any form of slavery, servitude, forced or bonded labour, or human trafficking (collectively referred to as 'modern slavery' in this statement).
   2. The LLP will not support any arrangement or relationship that is knowingly involved in modern slavery. We are committed to ensuring that there is no modern slavery in our business or in our supply chains, and to acting ethically and with integrity in all our relationships.
   3. The purpose of this statement is to set out the steps that the LLP takes to ensure that it and its supply chain (including contractors, suppliers, and business partners) do not engage in modern slavery.
   4. We consider the LLP's principal business of the sale and management of both residential apartments and office space to be very low risk. However, the development aspects of the site were considered to be low to medium risk through the extended supply chain involved in the redevelopment of the site.
2. Employees and members
   1. The LLP does not have any employees.
   2. The LLP's membership comprises corporate bodies reflecting its joint venture nature. It has no individuals as members.
3. Modern Slavery Policy
   1. The LLP has a Modern Slavery Policy. This covers, amongst other matters:
      • The LLP's approach to modern slavery;
      • Our commitment to transparency in the supply chain;
      • Compliance requirements;
      • Consequences for breach of the policy; and
      • Disclosure procedures and a commitment against retaliation/victimisation.
   2. A copy of the Modern Slavery Policy is available upon request.
4. Suppliers – an assessment of suppliers and the risk
   1. One of the members of the LLP is subject to a common ownership interest with the development manager, Native Land Limited, and which is the principal tier one supplier responsible for the arrangements made for the supply chain although many supply contracts are concluded direct between the supplier and the LLP. Native Land Limited has worked for many years with many of the main suppliers.
   2. The site is now post-completion. The main development contractor managing any defects during the warranty period, Osbourne, and the agents appointed to manage the estate, Lambert Smith Hampton, are both long established, reputable, and premier in their respective sectors. Each have their own modern slavery statements setting out their approach and the safeguards they employ. Other contractors/suppliers during the course of the year were:

      Supplier type	One-off or long term	Own Modern Slavery Statement?	Notes
      Interior fit-out and customer care businesses	One-off		Small business exemption
      Legal providers	Long term	Yes
      PR + communications agency	Long term	Yes

      These were all assessed as very low risk. The individual services providers are all small businesses and so exempt from the requirement to produce their own modern slavery statement. Given the nature of the services they provide and/or that the individuals provide the services themselves and without any, or any material further supply chain, these present as very low risk.   

   3. Other than those assessed as very low risk or for personal service, contracts with suppliers require them to comply with all applicable laws, statutes, regulations, and codes. This includes those relating to labour, anti-slavery and human trafficking laws, including but not limited to the Modern Slavery Act 2015. Any future contracts will contain explicit provision for this.
   4. A breach of those contractual obligations by the supplier would be treated with the utmost gravity by the LLP and could lead to sanctions up to and including termination of the contractual relationship.

This Modern Slavery Statement was approved by the LLP's members on 30 September 2022.

Signed:                                                                                                Dated: 30 September 2022

Philip John Blackman

Director of Designated member of Clan (Regent Property) LLP