Modern slavery is defined as a crime and a violation of basic human rights. Modern slavery can take various forms including (but not limited to) slavery, servitude, forced labour and human trafficking. This policy applies to people working for our firm, external consultants and suppliers.
Moorfield is a privately-owned real estate investment fund management business. We invest in a diverse range of real estate projects across the UK. Whilst we do not meet the turnover threshold set out under the Modern Slavery Act 2015 (Modern Slavery Act) requiring us to produce a Slavery and Human Trafficking statement, as part of our commitment to responsible and transparent investment management, we have opted to publish this policy statement which applies to all Moorfield Group companies.
We have a zero-tolerance approach to modern slavery and are committed to making investment decisions and managing our business in such a way that we minimise the risk of human rights infringements anywhere in our supply chain as well as comply with current legislation and seek to follow industry standards and best practice.
We require all our suppliers to provide services in a responsible manner and we conduct supplier screening on environmental, social and governance criteria as well as consistently review and strengthen our processes and systems to minimise this risk. While we consider the risk of abuse of the Modern Slavery Act by our UK based advisors to be minimal due to the nature of the service being provided, we are acutely aware of the greater exposure at asset level with any potential construction contractor and their employment of casual labour, any potential supplier providing imported manufactured products and any potential contract cleaners.
We commit to follow up with anyone who raises concerns regarding modern slavery and take the appropriate level of action, internally and/or externally as required. We take compliance with the Modern Slavery Act seriously and so we will review this policy statement on an annual basis to make sure it is still relevant and that any changes in legislation are reflected.
If staff have any concerns linked to modern slavery, these should be reported to their line manager and HR in the first instance. For any external parties, concerns should be reported to the firm’s Compliance Office who will in turn advise the firm’s Board
It is the responsibility of the Compliance Officer/ Finance Director to advise the Board of every modern slavery concern raised and to follow up on every such concern to ensure that the relevant parties and authorities (if relevant) have been informed. Compliance will also maintain a confidential register of all concerns raised, along with their outcome.
The firm’s Compliance Officer/ Finance Director has overall responsibility for ensuring this policy statement complies with our legal and moral obligations, as well as ensuring that our supply chain is aware of, and adheres to, our zero-tolerance approach to modern slavery.
This policy statement will be published on our Group’s website. In addition to publishing this policy statement, we conduct training sessions for our relevant staff where deemed necessary.
Any breach of this policy by our employees could result in disciplinary action (including dismissal) and reporting to external bodies responsible for law enforcement.
We will end our business relationship with individuals and/or organisations working on our behalf if they are found to be in breach of this policy and take no remedial action.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2023.
It was approved by Moorfield Investment Management Limited on 1st November 2023.
Steve Hall (Compliance Officer/ Finance Director)
1st November 2023