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 the year ended 31 March 2020 to prevent modern slavery and human trafficking in its business and supply chains. This statement will be reviewed and updated annually in September.
Our business and supply chains
KCCLP is the single landowner of the 67 acre King’s Cross Estate in London N1C. The partnership is made up of two entities: AustralianSuper (Australia’s largest 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 wide range of advisors and suppliers in the design and construction of the King’s Cross Estate, including masterplanners, designers and, crucially, construction contractors. Naturally, its supply chains are therefore fairly complex and include supply chains involving construction labour and materials. There are multiple levels of suppliers between KCCLP and the source of raw materials that are used in the construction process.
Much of the construction process inevitably involves a significant number of raw materials and personnel sourced by our suppliers and contractors from multiple locations. KCCLP has a zero-tolerance approach to human rights abuses and modern slavery. Given the nature of KCCLP’s supply chains, it is inevitable that KCCLP relies heavily on the safeguarding processes of its main contractors and suppliers to ensure that human rights abuses and incidences of modern slavery don’t occur in the supply chain.
Policies and contractual controls
KCCLP’s Anti-Slavery Policy strictly prohibits the use of forced labour, child labour and trafficked labour within its business and supply chain. The Anti-Slavery Policy sets out KCCLP’s zero tolerance approach to modern slavery and abuses of human rights.
KCCLP includes contractual obligations in the contracts with its main contractors and suppliers to seek to ensure that those main contractors and suppliers do not engage in modern slavery or use labour which is subject to human rights abuses. In addition, KCCLP requires all main contractors and suppliers to adhere to its Anti-Slavery Policy.
KCCLP’s contracts with its main contractors and suppliers include terms which entitle KCCLP to terminate its relationship with any main contractor/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).
KCCLP’s contractual documentation also requires contractors and suppliers to undertake regular reviews of their own supply chains and practices and to monitor related risks. In the event that any breach of KCCLP’s Anti-Slavery Policy is identified, the supplier in question must promptly notify KCCLP.
KCCLP requires all suppliers and contractors to adhere to (and confirm compliance with) KCCLP’s Anti-Slavery Policy. From due diligence undertaken to date by KCCLP, KCCLP understands that the majority of KCCLP’s main contractors and suppliers have adopted a similar policy to KCCLP’s Anti Slavery Policy within their own organizations. Indeed, our due diligence processes have demonstrated that many of our contractors and suppliers are adopting ‘best practice’ on modern slavery compliance.
Due diligence and audit of suppliers and supply chain
As part of its ongoing due diligence process, KCCLP reviews its list of contractors/suppliers and identifies and prioritises those entities by reference to (a) whether they are considered to be of ‘higher risk; and (b) the amount paid by KCCLP to the contractors and suppliers. Of its key suppliers, the construction contractors (the “Tier 1 Suppliers”) are KCCLP’s primary focus throughout the due diligence exercise as a result of (i) the high-risk nature of the construction sector; and (ii) their involvement in KCCLP’s business and supply chain. As the Tier 1 Suppliers handle so many elements of the procurement and construction process, as noted above, KCCLP inevitably needs to rely on the Tier 1 Suppliers’ respective anti-slavery policies and procedures in order to seek to ensure that modern slavery is not occurring in KCCLP’s supply chain.
As noted above, our due diligence processes have resulted in responses from our main contractors and suppliers which indicate that many of our contractors and suppliers have implemented extensive modern slavery compliance programmes and many are adopting ‘best practice’ on modern slavery compliance.
Modern slavery training
KCCLP has commenced a Modern Slavery Act training programme for relevant members of staff.
Further steps to prevent modern slavery in supply chains
Over the course of the year, KCCLP has taken the following steps to further prevent modern slavery in its supply chains:
- it has taken steps to ensure that it only enters into commercial relationships with companies who share its values and standards (particularly with respect to ethical labour standards); and
- it requires all new suppliers 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.
KCCLP acknowledges that the Covid-19 pandemic poses potentially new and increased modern slavery risks in its operations and supply chains. KCCLP is actively monitoring these risks and will ensure that it monitors and adapts its processes as necessary to seek to protect against these increased risks.
Steps to prevent modern slavery in supply chains in the next 12 months:
Over the next 12 month period, KCCLP intends to:
- Undertake a full review of its existing modern slavery processes in light of Covid-19 to ensure new and increased risks are fully understood and processes are in place or adapted to tackle these;
- review its supply chain in further detail to seek to gain a better understanding of the origin of its raw materials and the background of workers in the raw materials supply chain. The overall objective being to identify risk and implement actions to reduce the risks of modern slavery;
- conduct audits of its main contractors and suppliers (as appropriate) 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;
- review and implement additional training for all staff in roles which are most likely to be exposed to potential victims of modern slavery; and
- explore various industry initiatives aimed at eradicating modern slavery.
Assessment of effectiveness in preventing modern slavery
KCCLP will continue to review and evaluate the effectiveness of its measures throughout the upcoming year, taking into consideration: staff and supplier training levels; the degree of suppliers’ compliance with KCCLP’s policies; any incidents of modern slavery in KCCLP’s supply chain; level of communication between KCCLP and its Tier 1 Suppliers (and the same between suppliers and their sub-suppliers); and evidence of steps taken by KCCLP to address risks identified during its due diligence process.
No instances of modern slavery have been identified by KCCLP (in its supply chain) during the year.