This statement has been published in accordance with the Modern Slavery Act 2015 (the MSA), pursuant to Section 54(1), Part 6. It sets out the steps taken by King’s Cross Central Limited Partnership (KCCLP) and other relevant group companies during year ended 31 March 2017 to prevent modern slavery and human trafficking in its business and supply chains. This statement will be reviewed and updated annually.
Our business and supply chains
KCCLP is the single land owner of the 67 acre King’s Cross Estate in London N1C. The partnership is made up of two entities: AustralianSuper (Australia’s biggest pension fund) and Argent King’s Cross Limited Partnership (“AKX”). AKX is backed by Hermes Real Estate on behalf of the BT Pension Scheme, and Argent (Property Development) Services LLP (the asset manager and development manager for the King’s Cross Estate).
KCCLP has been developing the King’s Cross Estate since 2008 and has been involved in the full development process: identifying the site, developing designs and obtaining planning permission, securing finance, project management of the construction process and, eventually, asset management. It is delivering a mixed-use development of major commercial, residential, educational, cultural and community sites.
Although KCCLP is a UK-based entity, it works with a vast range of advisors and suppliers in the design and construction of the King’s Cross Estate, including masterplanners, designers and, crucially, construction contractors. As a result, its supply chains are often very complicated (particularly those involving construction labour and materials); there are often multiple levels of suppliers between KCCLP and the source of raw materials that enter the construction process.
Much of the construction process inevitably involves a significant number of raw materials and personnel from multiple locations. Consequently, identifying and handling all related risks is a very challenging undertaking. For this reason, KCCLP relies heavily on the safeguarding processes of its main contractors and suppliers in ensuring that human rights abuses and incidences of modern slavery don’t occur in the supply chain. In addition, it requires all suppliers to adhere to its Anti-Slavery Policy.
Policies and contractual controls
KCCLP’s Anti-Slavery Policy strictly prohibits the use of forced labour, child labour and human trafficking within its business and supply chain. The Anti-Slavery Policy sets out KCCLP’s zero tolerance approach to such abuses of human rights and reserves the right for KCCLP to terminate its relationship with any supplier in the event of non-compliance with its policy (and a subsequent failure by the supplier in question to address any breaches once identified and notified in respect of the same).
Henceforward, KCCLP will require all suppliers and contractors to adhere to (and confirm compliance with) KCCLP’s Anti-Slavery Policy, and will encourage them to adopt a similar policy within their respective organizations. KCCLP’s standard appointment documentation already requires suppliers and contractors to comply with all applicable legislation (which includes the MSA) and will be amended to require suppliers to undertake regular reviews of their own supply chains and practices and monitoring of the related risks. In the event that any breach of KCCLP’s Anti-Slavery Policy is identified, the supplier in question must promptly notify KCCLP of such occurrences.
Due diligence and audit of suppliers and supply chain
As part of its due diligence process KCCLP has compiled a list of its suppliers, identifying and prioritising those entities which submit the highest value and most regular invoices. Of its 13 key suppliers, the top three (in terms of invoice amounts) are the construction contractors (the “Tier 1 Suppliers”). Having ranked its other suppliers, KCCLP has selected 10 of its most regular professional advisors and consultants including architects, project managers, legal advisors and estate agents. KCCLP has contacted these 13 providers and requested information regarding each supplier’s approach to dealing with modern slavery within its organisation.
Due to the extent of their involvement in KCCLP’s business and supply chain, the Tier 1 Suppliers and their practices and policies have been KCCLP’s primary focus throughout the due diligence exercise. As they handle so many elements of the procurement and construction process, KCCLP is inevitably forced to rely on the Tier 1 Suppliers’ respective anti-slavery policies and procedures in order to satisfy its own obligations in respect of the legislation.
The statements submitted by the Tier 1 Suppliers in response to KCCLP’s enquiries set out the various steps that they have respectively taken to deal with the risk of modern slavery within their supply chains and operations, including the following:
- meeting with the anti-slavery commissioner to seek guidance and clarification on compliance with the MSA;
- establishing a Modern Slavery Steering Group with senior representatives from across the global business, to identify the risks and develop an action plan to address the same;
- co-founding the Supply Chain Sustainability School (which has its own Modern Slavery Interest Group to promote awareness of (and compliance with) the MSA);
- following audit guidelines relating to health and safety, fair wages and overtime when sourcing materials and labour from high-risk areas; and
- committing to:
- comply with UK and international legislation and operate in a manner consistent with the principles of the United Nations Universal Declaration of Human Rights, International Labour Organisation Declarations and the Global Compact;
- take steps to promote transparency of responsible procurement practice and actively engage clients and suppliers in this regard;
- comply with the standards of the countries in which they operate as a minimum;
- focus on recruitment processes to raise awareness amongst employees and the supply chain through education and communication; and
- provide training for employees and supply chain partners.
Once the remaining supplier responses have been received and reviewed, KCCLP will assess whether the areas of risk in its providers’ supply chains are being adequately identified and mitigated and, if not, will seek to work collaboratively with its suppliers in order to improve policies and practices and address the risk of modern slavery and human trafficking within the supply chain.
Assessment of modern slavery risk within our supply chain
Although it considers the majority of its business operations and providers to be relatively ‘low risk’, KCCLP has identified that its greatest risk with respect to modern slavery is within its supply chain: in particular, the high proportion of migrant workers working on its construction sites. Accordingly, KCCLP will continue to focus its due diligence efforts in the coming years on the Tier 1 Suppliers responsible for the construction programme at the King’s Cross Estate.
Modern slavery training
KCCLP has begun to increase its focus on modern slavery within its business operations and supply chains, partly by formulating its Anti-Slavery Policy. In addition to familiarising all employees and suppliers with these documents (and requiring suppliers to confirm adherence with them), KCCLP will establish a Modern Slavery Act training programme for relevant members of staff.
While KCCLP’s suppliers will be responsible for implementing appropriate training programmes in respect of their own employees and associates, KCCLP will require a key representative of each of the Tier 1 Suppliers to attend an accredited anti-slavery workshop or training session (such as Stronger Together’s “Tackling Modern Slavery in Global Supply Chains” workshop) and to provide evidence of such attendance. This will enable KCCLP’s most high-risk suppliers to detect and mitigate against the threat of modern slavery within the supply chain.
Further steps to prevent modern slavery in supply chains
Over the course of the coming year, KCCLP will look to take the following steps to further prevent modern slavery in its supply chains:
- seek to identify and enter into commercial relationships with companies who share its values and standards;
- require any new supplier tendering for work with KCCLP to provide details of its policies on slavery and human trafficking and provide assurances that it does not (and nor does any entity within its own supply chain) engage in slavery or human trafficking or any associated activity;
- refuse to enter into commercial relationships with entities knowingly involved with slavery or human trafficking;
- undertake a more detailed mapping of its supply chain in order to better understand the origination of its raw materials and the background of its labourers, with the aim of identifying and reducing the risks of modern slavery related to both;
- conduct annual audits of its main contractors and suppliers and review their controls and established processes, and assess their compliance;
- encourage a culture of whistle-blowing within its supply chain, including the provision of foreign-language awareness posters at each of its construction sites; and
- introduce an induction and periodic training programme for all relevant staff with KCCLP and AKX (the development manager).
Assessment of effectiveness in preventing modern slavery
KCCLP will review and evaluate the effectiveness of its measures throughout the upcoming year, taking into consideration: staff and supplier training levels; degree of suppliers’ compliance with KCCLP’s policies; level of communication between KCCLP and its Tier 1 Suppliers (and the same between providers and their sub-suppliers); and evidence of steps taken by KCCLP to address risks identified during its due diligence process.