Modern Slavery Statement

At the Devonshire Group, we take working conditions seriously. In line with the Group’s Core Values of ‘always improving’, ‘decency’ and ‘being inclusive’, the welfare, satisfaction and engagement of our employees and volunteers is of the utmost importance.

We have zero tolerance for modern slavery or unethical working practices, both within our own operations and our supply chain. Policies and procedures relevant to our employees and volunteers can be found within the Devonshire Group Colleague Handbook and the Devonshire Group Volunteer Handbook. This includes our Safeguarding Policy, Whistle Blowing Policy, Anti-Bribery & Corruption Policy, Anti-Bullying & Harassment Policy and Diversity & Inclusion Statement.

Supply chain

The Devonshire Group works with over 2,400 suppliers of goods and services. Our supply chain is highly complex, containing businesses of varying sizes and covering a wide range of sectors. The vast majority of suppliers are UK-based, and therefore subject to UK law. In 2022/23, 43% of spend was with suppliers less than 30 miles away.

All new and active suppliers are asked to agree to the Devonshire Group Supplier Code of Conduct. Based on the Ethical Trading Initiative (ETI) Base Code, the Code sets out our minimum expectations on working conditions and environmental protection. It covers the following standards:

1. 1. Employment is freely chosen
   2. Freedom of association and the right to collective bargaining are respected
   3. Working conditions are safe and hygienic
   4. Child labour shall not be used
   5. Wage payment meets national legal standards
   6. Working hours are not excessive
   7. No discrimination is practised
   8. Regular employment is provided
   9. No harsh or inhumane treatment is allowed
   10. Workers have a legal right to work in the country in which they are employed
   11. The environment is protected from harm

In 2022/23, expenditure on suppliers who have agreed to the Code or have an equivalent policy represented 85% of total supplier expenditure, those having agreed to the Code confirming they uphold the standards within their own business. We encourage suppliers to extend these expectations to their own supply chain.

Risk assessment and future action

While we ask all of our suppliers to agree to the Code, we acknowledge that exploitation is more prevalent in some industries than others. We plan to continue engaging with all suppliers who have yet to agree to the Code. Priority will be given to suppliers that present the highest risk.

We are fortunate to have a close relationship with our tenant businesses, and are confident that they take the issue of modern slavery as seriously as we do. We ensure that colleagues who engage with our tenants are aware of how to identify and report signs of modern slavery.

We also recognise the need to spread awareness among staff and plan to offer formal training to relevant colleagues, and establish mechanisms for taking action against Modern Slavery.

Update and review

This statement, and the actions set out within it, will be reviewed and updated annually.

Updated November 2023.