Modern Slavery act

Scape UK Management Ltd Statement on the Modern Slavery Act

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our anti-slavery and human trafficking statement for the financial year commencing 1^st October 24 and ending 30^th September 2025. This statement was approved by the Board on 8^th November 2024.

WHO WE ARE

Scape UK Management Ltd is a limited company registered in England and Wales under company number 12442982 and with its registered office at Lower Ground Floor Gardner House, Hornbeam Park Avenue, Harrogate, North Yorkshire, England, HG2 8NA. VAT number is 360029038.

Other associated companies that this statement applies to include: Scape Development Management Ltd (11720754) and Scape Operations Ltd (13719075).

We are fundamentally opposed to slavery and committed to understanding the risk of it and ensuring it does not occur anywhere within our business or supply chain.  We see this as fundamental to being a responsible and sustainable business; having trusted, open and valued relationships with our suppliers, Education Providers who partner with us and students who make us their choice for living while at University.

EMPLOYEES

The Company has over 184 employees (as at 2024). The employees operate the ten properties primarily in and around London, with 4,133 beds.

We have Code of Conduct and Ethics policies which (among other things) sets out our commitment to ensure all employment with us is on a voluntary basis. We ensure that our Code of Conduct and Ethics is regularly reviewed and updated. Our expectation that all employees conduct business in accordance with the highest standards of business and personal ethics, which includes always acting honestly, with integrity and without discrimination.

TRAINING

We reinforce the need to recognise the risks of anti-slavery and human trafficking in our business and supply chains through our employee induction and training. We provide guidance and training to support employee understanding of our values, brand and behaviours. Through our training programmes, employees are encouraged to identify and report any potential breaches of our anti-slavery and human trafficking policy.

Examples of training courses we have delivered over the past year include:

·      All employees have access to a suite of online training courses provided on a dedicated platform called LearnAmp.  On the platform is specific training modules which covers Fraud, Corruption and Modern Day Slavery including videos and articles.

·      Our senior management team received dedicated external procurement training focusing on ethical and responsible procurement practices.

·      This has been factored into our procurement procedure which includes an ESG Screening checklist alongside templates to ensure its implementation.

OUR SUPPLY CHAIN

Our supply chain comprises primarily UK based suppliers or specialist contractors providing goods or services in the UK. These are mostly property management related services such as property preventative and reactive maintenance, lifecycle works, as well as other technical services related to utilities, health & safety, IT etc. There are also real estate services such as development, construction and property refurbishment. We make sure our suppliers are aware of our policies, including our Code of Conduct, Scape Responsible Procurement Policy and our Scape Supplier Code of Conduct. We also require our business partners to provide training to their staff and suppliers and providers.

DUE DILIGENCE

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have the following due diligence procedures:

·      We have introduced ESG Screening Checklist where all third party service providers are required to complete. 

·      Responses are checked for completeness by the responsible person procuring the works and as part of the process, depending on the cost of works, need senior and board sign off.

Our procedures are designed to:

·      Establish and assess areas of potential risk in our business and supply chains;

·      Monitor potential risk areas in our business and supply chains;

·      Reduce the risk of slavery and human trafficking occurring in our business and supply chains; and

·      Provide adequate protection for whistleblowers.

MODERN SLAVERY RISK ASSESSMENT

We consider our highest risk areas in relation to slavery and human trafficking as being in our supply chain (rather than our employee base), particularly in connection with the sourcing by suppliers of construction materials, certain goods and the provision of manual labour in management services and property development. While nearly all our direct suppliers are based in the UK, some of these suppliers source certain materials from around the world. Where we have identified a potential risk, we undertake the following measures:

·      Through our procurement process we request all suppliers, existing and new, to undertake a ESG Screening Checklist review to demonstrate compliance with this policy.

·      This process has been provided and agreed by senior management and cascaded to all employees as required.

·      Where concerns are raised, contact details are provided where an escalation procedure is followed.  This may require, from time to time, and depending on the risk raised, will cause a supplier to no longer be part of our value chain unless remedial action is taken.

We continue to review this risk assessment and monitor our activity here as part our broader approach of ensuring we are a responsible and sustainable business.

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING

We use the following key performance indicators (KPIs) to measure how effective we have been in ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

·      Having a robust standard and process in place for the procurement of goods and services.

·      Setting a clear scope of works as detailed in our procurement process.

·      Means to evaluate supplier proposals in a systematic and consistent way.

Avoiding unrealistic turnaround times from suppliers and ensuring pricing is consistent and fair for the works sought.