ABOUT THIS POLICY
NALC Group Limited and its subsidiary companies are all committed to conducting their businesses in a socially responsible way. NALC businesses seek to carry out their operations in accordance with appropriate ethical standards and be honest and fair in their relationships with customers and suppliers. As part of this, NALC is dedicated to ensuring that effective systems and controls are in place to safeguard against modern slavery and human trafficking occurring within our businesses or any of our supply chain.
NALC GROUP SLAVERY AND HUMAN TRAFFICKING STATEMENT
In accordance with the Modern Slavery Act 2015 (“Act”), NALC has published this statement on behalf of its relevant subsidiary companies (“NALC”). This statement sets the steps that members of the NALC Group has taken to prevent modern slavery and human trafficking from occurring within its business and supply chains.
NALC Group Businesses
NALC through its subsidiaries is a leading provider of property services to its key customer groups:
- Services provided to consumers include real property auctions (buying and selling real property), property management services (lettings management, estate management, and build to rent investment).
- Services provided include compliance and business advice and provision of certain business services such as marketing material and websites.
NALC’s financial reporting includes three divisions:
- NALC Auctions Limited
- NALC Learning Centre
- NALC Social Media
- NALC Social TV
As at 30th June 2021, NALC through its subsidiaries employed circa 40 people across the UK, where its business operations are entirely based.
NALC Group Supply Chains
Members of NALC Group have established direct relationships with a number of primarily UK-based suppliers who deliver a variety of services including: professional services, utilities and telecoms, and facilities management. As part of its service delivery, members of NALC Group procure services not just for themselves, but also for the benefit of some of the customers of other group companies (for instance, engaging contractors to provide maintenance services to properties managed by the Group).
The vast majority of services are procured via specialist individuals employed or engaged by members of the NALC Group (senior team managers and heads of service).
NALC Group Policies and Contractual Provisions
The approach of members of NALC Group to the promotion of human rights and ethical issues is contained within NALC HR Policies which include but not limited to:
- Anti-Bribery and Corruption Policy
- Equal Opportunities Policy
- Recruitment Policy
- Whistleblowing Policy
- Grievance Policy
- Anti-Bullying and Harassment Policy
The NALC HR policies apply to all individuals employed or engaged by NALC and our subsidiaries. Employees can use the whistleblowing policy to report suspected concerns within the NALC businesses and supply chains.
Since the enactment of the Act members of the NALC Group have taken steps to seek to ensure that any new agreements with suppliers include an express obligation for suppliers to comply with the Act, to implement due diligence procedures within its own supply chains and notify NALC in the event of any actual or potential incidence of modern slavery (for instance, when contractors sign up on NALC Property Management’s portal they agree to terms which require them to comply with the Act). In the event of a breach of these provisions, members of NALC Group will seek to resolve any issues with its suppliers and it may also seek to terminate the relationship with the supplier where a resolution is not achieved. This provision is regularly reviewed, and relevant amendments made.
NALC Group Due Diligence
Members of the NALC Group have identified our supply chains as the main area of risk and exposure to modern slavery.
The suppliers used by NALC Group have been identified as low risk. The suppliers which provide manufactured goods to NALC Group are very few, limited to marketing and advertising providers (providing banners, posters etc), and facilities providers (providing toiletries, vending machine and drink machine products etc.) Other suppliers to NALC Group mainly provide in-person services, such as maintenance services and recruitment services. Contractors used by NALC pass through an on-boarding process, which includes terms requiring them to comply with the Act and provide a copy of their modern slavery statement where requested.
NALC Group Areas of Risk
Overall exposure to modern slavery for members of the NALC Group is lower than other sectors given the nature of the property services sector in which our businesses operate, the types of services we procure and the fact that our business operations and those of the majority of our suppliers are primarily based in the UK.
Notwithstanding the above, NALC Group is not complacent and understands that the procurement of recruitment and facilities services and the use of subcontractors are practices which may bring about increased risks of modern slavery within supply chains.
Accordingly, NALC is taking steps to mitigate such risks, including:
- Requiring suppliers to implement due diligence procedures for its own suppliers and subcontractors.
- Having in place stringent checks on our recruitment agencies and ensuring our own internal recruitment processes meet the minimum legal requirement.
As part of this, NALC Group complies with all relevant legislation including the Immigration, Asylum and Nationality Act 2006 and ensures that all appropriate checks are carried out to maintain compliance. If further risks are identified, NALC Group will consider such risks and take appropriate steps to address any emerging risks.
NALC Group Training
NALC Group understand the importance of training employees to enable them to be able to identify risks of modern slavery. NALC Group employees receive information that allows them to understand the requirements under the Act in the form of this policy. They also receive our whistleblowing policy, which would allow them to raise concerns anonymously.
The NALC Board appreciates that the approach to combatting modern slavery will have to adapt over time in response to findings following the completion of various risk assessments.