Modern Slavery and Human Trafficking Statement
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. The statement applies to Hammerson plc (“Hammerson”), its subsidiaries and joint venture investments in the United Kingdom where Hammerson acts as asset manager (“the Group”) for the financial year ended 31 December 2017. It sets out the approach taken by Hammerson to understand the potential modern slavery risks related to its business and explains the actions taken to prevent slavery and human trafficking within the Group’s supply chains and own business.
Our business and supply chains
At Hammerson, we create destinations that excite shoppers, attract and support retailers, reward investors and serve communities; destinations where more happens. Our portfolio includes investments in prime shopping centres in the UK, France and Ireland; convenient retail parks in the UK; and premium outlets across Europe. We are a responsible owner, manager and developer of retail property and have a sustainability vision and strategy, called Positive Places, to create retail destinations that deliver positive impacts economically, socially and environmentally.
In 2017 we were the first real estate company to commit to become Net Positive for carbon, resource-use, water and socio-economic impacts by 2030. This involves establishing clear five year targets in each of these areas which will be closely monitored and further details on this commitment are included in our 2017 Sustainability Report.
Our Group-wide risk management approach, which includes risks associated with our supply chain, is explained in our 2017 Annual Report and provides a robust foundation for identifying risks, assessing mitigation actions and establishing clear management responsibility. In our supply chain we have identified our key risk areas to be construction activities and low-skilled support services such as cleaning.
Our supply chain policies
We have a Responsible Procurement Policy which demands that businesses in our supply chain comply with all applicable laws and our Supplier Code of Conduct. This code requires suppliers to provide their employees with a written contract in their local language stipulating employment terms and conditions and to provide employees with a safe workplace free of discrimination, harm, intimidation, harassment and fear. Before engaging a new supplier, we complete due diligence on the organisation including health, safety, environmental and labour practices and will not engage with organisations who fall below the Group’s required standards.
Additionally, for contracts over £100,000 we require suppliers to complete our Positive Places Supply Chain Survey which includes a declaration that the organisation complies with labour standards. The survey has been enhanced and the results are published in our Annual Supplier Report.
We have identified a number of key shopping centre suppliers who provide portfolio-wide services including cleaning, maintenance, project management, telecommunications and IT. We work with these suppliers to encourage them to pay their employees wages which are above local market levels. Contracts with these suppliers include clauses explicitly stating that they will comply with anti-slavery laws and they do not engage in any slavery or human trafficking practices. We also require the supplier to notify us of any potential breaches of which they become aware.
We also take our responsibilities to our suppliers seriously and are a signatory to the UK Government’s Prompt Payment Code and have due regard to the RICS Code of Practice when managing service charges.
Hammerson is an equal opportunities employer and does not discriminate between local and migrant employees. We directly employ fewer than 600 people across the Group and enjoy high levels of employee retention, engagement and development. We expect our employees to operate in line with
our Code of Conduct which requires employees to treat other people with respect and to comply with all laws and regulations. We also have a Whistleblowing Policy under which employees are encouraged to report any suspected wrongdoing and are also able to seek confidential advice from the independent charity, Public Concern at Work.
During 2017, we developed the next phase of our Diversity and Inclusion strategy and we delivered a series of all employee events. These promote greater diversity and a more inclusive working environment across the Group.
We also carried out the first stages of Modern Slavery awareness training with UK and Ireland Shopping Centre Teams including how to report any issues. During 2018, we intend to extend this training to all new and existing employees across the Group using our new online training system.
Effectiveness measured against performance indicators
Our annual Corporate Responsibility report includes information on how we have delivered positive economic, social and environmental impacts. While we do not use key performance indicators specifically for slavery or human trafficking, we believe that our policies, practices and actions have been effective in preventing slavery and human trafficking during 2017. As explained in our previous statement, we enhanced a number of our policies and procedures in this area during 2017, and have a number of further improvements planned for 2018.
We continue to conduct our business affairs to a high standard of integrity, honesty and transparency. As a FTSE4Good listed company, we are committed to making a positive impact on the economy, society and environment. This includes working to ensure that slavery and trafficking do not exist in our supply chains and work places. We review our effectiveness in this area each year and make public our findings through the publication of this annual statement.
This statement is approved by the Hammerson plc Board on 25th June 2018.