Slavery and human trafficking statement for the financial year ending 31 March 2025
We are Places for People (the “Group”), the UK's leading Social Enterprise. We change lives by creating and supporting thriving Communities. Our business consists of complementary companies that are market leaders in homes and communities, regeneration and development, investment management, property management and leisure.
The Group comprises of 13,000 People who create, manage, and support thriving Communities across 245,000 homes - including 74,000 for social rent through the largest development pipeline in our sector, in over 100 leisure centres, and for over a million Customers.
Using the power of partnership and working collaboratively, almost 13,000 colleagues in more than 20 specialist companies create Communities and provide People with opportunities and choice in a way that few organisations can match and we arrange our activities so that clients, Customers and Colleagues regard all parts of the Group as a single business.
The Group has noted the requirements of the Modern Slavery Act 2015 (the "Act"). This statement is made on behalf of the Group parent, Places for People Group Limited (company number 03777037), and the Group as a whole. The following subsidiaries in the Group are either required to make their own statement under the Act or have volunteered to do so and have adopted this statement:
- Places for People Developments Limited (company number 04086030);
- Places for People Homes Limited (registration number IP19447R);
- Places for People Leisure Limited (company number 08363432);
- Places for People Leisure Management Ltd (company number 02585598)
- Places for People Living+ Limited (registration number IP20014R);
- Allenbuild Limited (company number 01248351)
- PfPL (Holdings) Ltd (company number 04832063);
- Zero C Group (2008) Limited (company number 07465675);
- Zero C Holdings Limited (company number 06540829);
- Residential Management Group Limited (company number 01513643);
- Derwent Facilities Management Limited (company number 07264667);
- Castle Rock Edinvar Housing Association Limited (registration number SP1767RS);
- Places for People Scotland Limited (company number SC278428); and
- Thriving Investments Limited (company number 09571845).
Our core businesses
We operate across the whole of the property value chain from initial procurement of sites, through planning and project management to the delivery of high-quality places with supporting infrastructure and strong management.
We deliver services to a range of stakeholders including tenants, landlords, house buyers, local authorities, investment fund managers and leisure centre users.
Our supply chain
Our large and varied Group business offering is reflected in the breadth and complexity of our UK supply chain that has more than 7,000 established suppliers We engage with a wide variety of organisations for a broad range of goods and services - primarily corporate, construction and property related, but also some more specialist requirements.
Our supply chain members are diverse not only in the goods and services they provide, but also in the size and structure of their organisations - from the very small microbusinesses and SME’s to multi-national and international corporations. We actively encourage smaller businesses to apply to join our supply chain to promote local business initiatives in the UK.
Our policies to resist modern slavery and human trafficking
We are confident that our policies promote good behaviour among our Colleagues at work and within our supply chain. Our policies and procedures are kept under review to make sure that they reflect the changing shape of the Group and of the needs of the people and markets it serves in the UK.
We review the risk and effectiveness of our controls at least annually.
In our own businesses
The policies that we consider give us strength in avoiding modern slavery or human trafficking
under the Act in our businesses are:
- Procurement Policy;
- Supply Chain Code of Conduct;
- Recruitment & Selection Policy;
- Health & Wellbeing Policy;
- Equality, Diversity and Inclusion Policy;
- Whistleblowing Policy (which makes clear that a report of concern in relation to modern slavery or human trafficking can be made under the protection of the policy);
- Behaviour at Work Policy (which covers conduct at work including fraud response, gifts/hospitality and personal interests);
- Bullying & Harassment Policy;
- Conduct Policy; and
- Group Safeguarding Standard.
We continue to provide a confidential reporting line accessible to all Colleagues (employees, workers, consultants, agency and self-employed contractors), which provides a further route for grievances or whistleblowing complaints to be raised. Cases can be anonymous if preferred with the identity/contact details known only by the external provider.
We continue to carry out right to work checks, under our obligations to prevent illegal working.
The Bullying & Harassment policy enhances our message around equality, diversity and zerotolerance of harassment or discrimination.
In our supply chain
We are determined that there shall be no modern slavery or human trafficking in our supply chain.
Our Supply Chain Code of Conduct and sustainable procurement policies evidence our commitment to act ethically and with integrity throughout our business relationships and all suppliers, no matter how long-standing, are required to abide by them.
Acceptance of the code of conduct is embedded into our supplier onboarding process for all suppliers across the Group to ensure we have a robust and consistent approach to modern slavery. The code outlines explicitly to the supply chain what is expected of them in terms of their behaviour and their responsibilities to the Group. It expresses our culture and values and how we expect suppliers to engage with us on matters of modern slavery, reporting and safeguarding.
Our code of conduct reflects the requirements of the Act. We have published it on our website, referred to it on all new supplier forms, and notified supply chain members of its existence through our on-line channels to ensure that all suppliers are aware of our expectations. As part of any new vendor selection questionnaire when tendering, adherence to the Act is a mandatory requirement for any new suppliers working for the Group.
As with previous years, we have continued to engage with Unseen the leading charity, whose vision is a world without slavery. We have continued this engagement specifically across our construction businesses. We have engaged with Unseen to provide training to contractors and subcontractors on modern slavery across one of our major construction frameworks to further highlight the Group’s position on modern slavery and our desire to help educate others on the topic.
We also conduct modern slavery audits, using the Chartered Institute of Procurement and Supply (CIPS) templates. With over 7,000 suppliers this will always be an iterative and ongoing process.
These audits will be more focused on high-risk areas tailored to specific industries as advised from the expertise of Unseen. We will continue to do this in a positive and proactive way to support the supply chain to meet its requirements in relation to the Act.
Our intention is to create a much wider understanding of modern slavery across the organisation that often makes “buying decisions” at potentially smaller and more local levels. This will create a much wider knowledge in the business of risk management, mitigation and due diligence, identifying hot spots and trends, giving greater supplier engagement and supporting the evolution of policies and practices.
We have contracts with supply chain members and in many cases those contracts are for several years' duration. We have introduced a contractual requirement for suppliers that they do not engage in any activity that is contrary to the Act. Where a contract has been renewed during the year, or any new contract has been formed, that requirement has been applied, with newly enhanced terms and conditions giving the supplier greater responsibilities and the Group significantly enhanced scope to insist on changed behaviour or to terminate the relationship where the Act is deliberately breached. Every supplier (whether on a new contract or one formed before the Act came into force) knows that we expect them to avoid modern slavery practices because they are required to abide by the code for supply chain partners.
Training and continuing vigilance
We have developed our protocols with our procurement supply chain to promote awareness and will continue to do so. Our aim is to share knowledge so that more people are more alive to the relevant risks of Modern Slavery and know what to do if they have a concern.
We operate mandatory modern slavery e-learning training for our all our workforce, which staff are required to complete every 12 months, and we monitor compliance across the Group. The training is designed to raise awareness of modern slavery, including what signs to look for, how this may be relevant to their business activity and how to report any suspected cases. In addition, all managers within the Group attend a 12-month leadership development programme and receive introductory training on modern slavery as part of the managerial responsibilities section.
Declaration
This statement is made pursuant to section 54(1) of the Act for the financial year ending 31 March 2025 (1 April 2024 to 31 March 2025). It has been approved by Places for People Group Limited’s board of directors on 21 May 2025 and the boards of directors of each of the Group’s subsidiaries required to make a statement under the Act.
Signed by MICHAEL GREGORY REED, in his capacity as Group Chief Executive of Places for People Group Limited.
Date: 21 May 2025.