Introduction
At Far East Consortium, we are committed to ensuring adherence to the highest legal and ethical standards. As a group, we have published this statement outlining the steps we have taken to ensure slavery and human trafficking are not taking place in our business or within our supply chain. This reinforces our commitment to being a responsible business whilst addressing our own obligations under the Modern Slavery Act 2015.
Organisational structure
This statement covers activities undertaken to prevent modern slavery and human trafficking by UK subsidiaries of Far East Consortium International Limited (a full list is available at the end of this statement) during the year ending 31st March 2018. The statement also sets out plans for the coming year to ensure further steps are taken over 2019.
Within the UK, we are a leading property developer, specialising in residential and hotel developments. Our ultimate parent company is Far East Consortium International Limited.
Supply chain
Our supply chains include: design and engineering consultants, construction contractors, suppliers of furniture, fixtures and equipment, building maintenance/service contractors, professional service providers (such as lawyers and accountants), IT service providers, marketing and design agencies and recruitment agencies.
High-risk activities
As a property developer operating within the UK, we believe that the following areas of our business are most at risk of being affected by slavery and human trafficking: our direct-hire employees, contractors, subcontractor operatives, and the workforce of our supply chain.
The steps that we take to mitigate risks in relation to each of these areas are as follows:
Employees:
• We verify that all employees have the right to work in the UK upon commencement of their employment.
• We make all employees aware of their working hours, leave and absence entitlements and other employment benefits.
Contractors and Subcontractor Operatives:
• We require Contractors and Subcontractors to ensure their employees have the right to work in the UK.
• We consider Contractor’s and Subcontractor approaches to employee rights and any breaches of human rights related legislation during our selection process.
• We want all Contractors and Sub-contractors that purchase materials for use on our sites to consider the risk of modern slavery in their supply chain.
• We require confirmation of compliance with Modern Slavery legislation from of our supply chain, and this is to be evidenced each year through our supplier management process
Suppliers:
• We procure the majority of our directly sourced materials from UK based organisations that are required to comply with UK laws on forced labour.
Responsibility
Responsibility for the company’s anti-slavery initiatives is as follows:
• Policies: Our Human Resources department are responsible for putting in place and reviewing policies, seeking involvement and expertise from relevant departments when needed.
• Due diligence: Our procurement department are responsible for managing existing and future suppliers. As part of our supplier management process we will ensure that each supplier provides evidence of compliance with relevant legislation, and we will stipulate that to be on our supply chain, our sub-contractors must have robust procedures in place to prevent any slavery and human trafficking.
• Investigations: In instances of suspected slavery or human trafficking within our supply chain, the Legal department, in co-ordination with the Procurement department, will be responsible for leading any required investigation. When the matter is internal, the HR department will be responsible for leading the investigation, involving the Legal department when needed.
Relevant policies
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
Whistleblowing policy
– We encourage all of our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, Far East Consortium. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The company’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can use our confidential helpline/complete our confidential disclosure form.
Business Code of Conduct
– Our code makes clear to employees the actions and behaviour expected of them when representing the company. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating and managing our supply chain.
Recruitment policy
– Our recruitment policy sets out our obligations for completing right to work checks for new and existing employees, preventing illegal working in the UK and mitigating risks of slavery and human trafficking.
Due diligence
We undertake due diligence when considering taking on new suppliers, and regularly review our existing suppliers. Our due diligence and review processes include:
• evaluating the modern slavery and human trafficking risks of each new supplier;
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• taking steps to improve substandard suppliers’ practices, including providing advice to suppliers through a third-party auditor and requiring them to implement action plans; and,
• invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
Training
On joining FEC UK all permanent and fixed term contract employees are made aware of our Business Code of Conduct and Whistleblowing Policies. All employees have access to the Group’s policies and procedures including those on diversity and inclusion, health and safety and bullying and harassment. To ensure that our employees have a high level of understanding, we intend to provide guidance and training on modern slavery and human trafficking.
Evaluating Performance
Whilst we believe that the risk of modern slavery within our direct operations is low, we recognise the need to set best practice standards for our supply chain and to regularly monitor and evaluate their performance. We remain committed to demonstrating strong environmental, social and governance practices. In the year ahead we will continue to raise the awareness of modern slavery to our employees, engage with and review supplier performance.
List of UK Subsidiaries
• FEC Northern Gateway Development Limited
• Northern Gateway Operations Limited
• Northern Gateway (FEC) No. 1 Limited
• Northern Gateway (FEC) No. 2 Limited
• Northern Gateway (FEC) No. 3 Limited
• Northern Gateway (FEC) No. 4 Limited
• Northern Gateway (FEC) No. 5 Limited
• Northern Gateway (FEC) No. 6 Limited
• Northern Gateway (FEC) No. 7 Limited
• Northern Gateway (FEC) No. 8 Limited
• Northern Gateway (FEC) No. 9 Limited
• Angel Meadows (FEC) Limited
• Angel Meadow Management Company Limited
• Angel Meadow Commercial Limited
• FEC Development Management Limited
• Crouch End (FEC) Limited
• Crouch End Management Limited
• FEC Time + Space (UK) Limited
• FEC Overseas Investment (UK) Limited
• Trans World Casinos (UK) Limited
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