mila-ai4h/AIMS.au huggingface dataset:
[SID_589] The only suppliers we use outside of the UK and EU are our digital screen suppliers in China
[SID_589] Training and Risk Awareness Wildstone introduced training to raise awareness and ensure that all staff have a basic level of understanding of modern slavery and what to look for in their respective roles
[SID_589] For all existing staff, Wildstone is aiming to ensure that they complete this basic training by the end of Q1 in 2024 and that all new staff complete the training as part of their onboarding
[SID_589] An independent whistle blower hotline for internal and external parties to alert Wildstone to risks including human rights abuses
[SID_589] Due Diligence Processes Wildstone has assessed the risk of modern slavery from our supply chain in the UK and EU to be low given the highly regulated nature of the environment in which Group companies are operating
[SID_589] Nonetheless, Wildstone has instigated a supplier questionnaire to understand the companies we are contracting with and the workers within our supply chain in order to assess risk at a company level
[SID_589] The only major supplier not based in the UK or EU in our supply chain is our digital screen supplier that is based in Shenzhen, China
[SID_589] China has a vulnerability score of 45.5 (out of 100) based on the Walk Free global slavery index and the UN has identified widespread evidence of state-sanctioned modern slavery in Tibet and Xinjiang, China, homeland of the Tibetans and Uyghurs
[SID_589] Wildstones manufacturing partner is a private owned company based in Shenzen, China
[SID_589] Prior to entering into a manufacturing and supply agreement Wildstone undertook inspections of its manufacturing and workers facilities
[SID_589] In addition, we have taken steps to ensure that the extended
[SID_589] supply chain does not source components from regions in China with a higher risk of modern slavery or forced labour
[SID_589] The due diligence steps undertaken by Wildstone has not identified any indications of modern slavery or forced labour in our supply chain
[SID_589] Relevant Policies Wildstone has adopted the following policies relevant to this statement
[SID_589] Modern Slavery Policy
[SID_589] Whistleblowing Policy Key Performance Indicators We will continue to monitor working conditions in our supply chain through the following
[SID_589] Providing awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking
[SID_589] Requiring staff involved in procurement activity are aware of and follow modern slavery procurement guidance on GOV.UK
[SID_589] Ensuring that consideration of the modern slavery risks and prevention are added to Wildstones policy review process as an employer and procurer of goods and services
[SID_589] Continuing to take action to embed a zero tolerance policy towards modern slavery; and
[SID_589] Requiring staff involved in buying or procurement and the recruitment and deployment of workers receive training on modern slavery and ethical employment practices This Statement was prepared for the 2023 financial year and was approved at Wildstones Board on the 16th November 2023
[SID_589] Wildstone is not aware of any issues in its supply chain that contradict this Statement
[SID_589] Philip Allard Chief Operating Officer 16th November 2023
[SID_593] TIAA International Holdings 2 Limited Slavery and human trafficking statement for the financial year ended 31 December 2021 Introduction This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (MSA) and applies to all subsidiaries within TIAA International Holdings 2 Limited (Nuveen or the Group) (including those incorporated outside of the UK in Europe and APAC)
[SID_593] Our business Nuveen has supported the financial futures of millions of investors for over 120 years
[SID_593] Under the leadership of TIAA, we invest in the growth of businesses, real estate, infrastructure, farmland and forests while building long-term relationships with clients from all over the globe
[SID_593] With expertise across income and alternatives, and as one of the first in the industry to practise responsible investing, we continue to expand our capabilities while maintaining our legacy as a leading investment manager
[SID_593] Our investment specialists offer deep expertise across traditional and alternative investments through a wide range of vehicles and customized strategies
[SID_593] As of 31 March 2022, across the whole Nuveen group (including affiliates), Nuveen has $1.2 trillion in assets under management and operations in 27 countries
[SID_593] Our asset management activities are conducted by regulated entities* which adhere to high standards of governance
[SID_593] Further information about the nature of our business can be found here * Financial Conduct Authority in the UK, Monetary Authority of Singapore, Commission de Surveillance du Secteur Financier in Luxembourg, the Securities and Futures Commission in Hong Kong, the Japan Financial Services Agency and the Australian Securities and Investments Commission Our approach and commitment We strive to be an engaged, influential and active corporate citizen in the business of tomorrow
[SID_593] We approach this by staying true to our values of performance, collaboration, innovation, integrity, passion and personality and by maintaining good governance standards and processes at the corporate, fund and asset level
[SID_593] We are committed to ensuring that there is no modern slavery or human trafficking in our business or within supply chains across the globe
[SID_593] Various policies are in place across the business to ensure compliance with laws and regulations and to ensure our values on ethical matters are understood by our employees
[SID_593] These include policies on anti-bribery and corruption, whistle blowing, health and safety and employment policies and procedures in relation to equal opportunities/diversity, recruitment, health and safety and employee behavior
[SID_593] We shall continue to review the current policies, procedures and training initiatives for our business in order to ensure that they fully reflect our commitment in relation to modern slavery
[SID_593] Supply chain Financial/professional services suppliers The Group engages with numerous suppliers in relation to its day to day operations, including financial and professional services organisations (such as banks, lawyers and accountants)
[SID_593] A supplier approval procedure is in place to ensure that such suppliers are taken on in line with policy and we expect all of our suppliers to act in an ethical manner with integrity in relation to human rights issues
[SID_593] The nature of services provided makes such DocuSign Envelope ID: FB4390C3-7D11-45E1-925A-BF950C3F2A2F
[SID_593] supplier risk low in relation to modern slavery
[SID_593] Due diligence processes are in place to ensure that internal standards are in place and maintained
[SID_593] Office services suppliers In the UK, the Group currently sub-lets its main office space from another lessee and has no direct supply chain in relation to facilities, office and cleaning services for such principal office space
[SID_593] Other suppliers We appoint reputable management companies to manage the properties and developments that we are involved with
[SID_593] All property managers are required to register with our monitoring system where they are asked to provide information on their compliance with various laws and regulations, including answering questions directly related to modern slavery and human trafficking
[SID_593] Where we find evidence of modern slavery occurring within our supply chain, we will require the supplier to implement appropriate actions or otherwise seek to terminate our relationship with the relevant supplier
[SID_593] Risk As a global business, we are committed to ensuring an appropriate risk-based strategy to investment management, including consideration of the risk of modern slavery and human rights offences
[SID_593] Employees Employee handbooks are available to all staff providing guidance on the Groups employment practices
[SID_593] There is a recruitment process in place to ensure the process is as fair and equitable as possible and not discriminatory
[SID_593] All potential employees are subject to rigorous employment checks to ensure their suitability for the position and that they are authorised to work in the jurisdiction within which they will be employed
[SID_593] Salary benchmarking is undertaken in order to ensure individuals pay adequately reflects the work being undertaken
[SID_593] Michael Sales Director For and on behalf of the Board 30 June 2022 DocuSign Envelope ID: FB4390C3-7D11-45E1-925A-BF950C3F2A2F
[SID_595] PHP plc Modern Slavery Statement 2024
[SID_595] PRIMARY HEALTH PROPERTIES PLC
[SID_595] MODERN SLAVERY STATEMENT 2024
[SID_595] INTRODUCTION This is the annual statement published by Primary Health Properties PLC (PHP) in accordance with its obligations under the Modern Slavery Act 2015 (the Act)
[SID_595] PHP fully supports the Acts objectives to combat slavery and human trafficking and improve the transparency of reporting on modern slavery
[SID_595] This Statement relates to PHP and its subsidiaries (the Group) and is made in respect of its financial year ended 31 December 2023
[SID_595] It sets out the steps PHP has taken, and is proposing to take, to address the risk of slavery and human trafficking taking place in its business and within its supply chain
[SID_595] OUR BUSINESS AND ORGANISATION'S STRUCTURE PHP is a FTSE 250 listed Real Estate Investment Trust which specialises in the ownership of modern purpose-built healthcare facilities, the majority of which are leased to the NHS in the UK and HSE in Ireland
[SID_595] The Groups portfolio consists of over 500 properties across the UK and Ireland and is valued at 2.8 billion
[SID_595] In 2023 PHP had 58 direct permanent employees in the UK
[SID_595] The business operations consist of finance and office functions, property and facilities management, asset management and investment and development
[SID_595] All staff are professionally qualified (predominantly surveyors and accountants / finance professionals)
[SID_595] At the start of 2023 PHP acquired Axis Technical Services Limited (Axis) based in Cork, Republic of Ireland
[SID_595] Axis provides property and facilities management services across Ireland and is responsible for managing PHPs portfolio of healthcare buildings in Ireland
[SID_595] Axis employs 28 staff across support and technical building maintenance and management roles
[SID_595] Our business is predominately within the UK and accordingly our direct geographic risk of slavery and human trafficking is considered to be low
[SID_595] OUR SUPPLY CHAIN The Group has approximately 1,200 suppliers that support our property and asset management, development and corporate activities
[SID_595] Our construction and property maintenance supply chain is where we believe the main risks of slavery and human trafficking may arise and in particular where lower skilled trades may be used and where certain materials or products may be sourced from outside of the European Union (EU)
[SID_595] PHPs construction projects tend to be smaller new developments or refurbishments of existing primary healthcare facilities
[SID_595] These smaller projects tend to have smaller numbers of workers on site
[SID_595] Following recent audits of live sites, we believe there is less risk with these size of projects as they do not lend themselves to large gangs of workers being used by contractors
[SID_595] PHP purchases very few materials directly, and the majority of materials are sourced through our contractor supply chain and are specified to meet the needs of our NHS and HSE occupiers in the UK and Ireland
[SID_595] Some materials sourced from outside of the EU may have risks of modern slavery or related issues in countries of origin
[SID_595] For example, we have completed work to review solar PV products being used for refurbishment projects and identified some which have links with the
[SID_595] PHP plc Modern Slavery Statement 2024 Xinjiang region of China, identified as higher risk in relation to human rights issues
[SID_595] PHP does not consider its risks associated with other suppliers, such as lenders, accountants and other professional service providers, to be material
[SID_595] We will continue to develop our understanding of potential risks in our supply chain and take appropriate action where risks are identified
[SID_595] These risks are shared across industry and so where relevant we will collaborate with others to share information and learning
[SID_595] OUR POLICIES PHP is committed to conducting its business in a lawful and ethical manner
[SID_595] In particular, PHP will not tolerate slavery and human trafficking
[SID_595] PHP applauds, and seeks to support, efforts being made globally to eliminate such practices
[SID_595] Our Business Ethics Policy sets out overarching commitments and requirements which we will abide by, including on human trafficking and modern slavery, and we expect our supply chain and partners to uphold these standards too
[SID_595] Incidents of modern slavery and forced labour in the UK have increased in recent years and in recognition of the importance of taking a proactive approach, we adopted an Anti-Slavery and Human Trafficking Policy during 2022, which reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains
[SID_595] Our policies can be viewed on our website under Responsible Business and we will monitor and update these as necessary
[SID_595] PHP expects its suppliers, contractors and service providers (suppliers) to also support the elimination of such practices
[SID_595] We expect all of our suppliers to comply with our policy and a copy has been sent to them
[SID_595] WHAT WE HAVE DONE DURING 2023 We communicated with all of our suppliers (for property and facilities management, asset management and development), sharing our ESG policies and specifically our Modern Slavery policy, to ensure they are aware of them and the issues they relate to
[SID_595] We required suppliers to respond to us to confirm they will operate in accordance with our policies and as at 31 December 2023 had received confirmatory responses from approximately 80% of these
[SID_595] We will continue to follow up on this and will engage any new suppliers in the same way
[SID_595] We continued to review our supply chain with a view to minimum standards through our membership of SafeContractor, which we require all our contractors to be accredited to
[SID_595] We engaged with our suppliers who were not yet accredited and increased the level of accreditation during the year
[SID_595] SafeContractor accreditation includes specific requirements related to modern slavery and we continued to track performance of our supply chain
[SID_595] As of December 2023, 275 (December 2022: 225) had met the requirements, representing over 90% of our current suppliers
[SID_595] All employees involved in projects or procurement completed training on modern slavery and business ethics
[SID_595] PHP plc Modern Slavery Statement 2024 In order to strengthen our due diligence approach, we commissioned independent ethical labour audits on two live construction projects (a refurbishment and a new development)
[SID_595] Working with a third party, Achilles, the audits are unannounced and consist of private worker engagement surveys and visual site inspections to understand and assess labour practices
[SID_595] No serious issues were identified although some more minor issues were raised, which PHP then communicated with contractors about to ensure they follow up
[SID_595] We identified solar PV as a common product being procured via contractors for our buildings with potential risks in the supply chain
[SID_595] Principal risks are related to forced labour linked with the production of polysilicon in some regions
[SID_595] Following a review of past products installed, we identified that some may be from regions posing a risk
[SID_595] We produced a response protocol for use on new build and refurbishment construction sites
[SID_595] This outlines the steps that should be taken should an instance of modern slavery be suspected or identified on a site to ensure the safety of potential victims and to capture learning for PHP and the project team
[SID_595] WHAT WE PLAN TO DO IN 2024 We will continue to communicate with suppliers regarding our policies, including on anti-slavery and human trafficking and require them to confirm their understanding and their own approach
[SID_595] We will encourage suppliers to undertake training on modern slavery awareness and continue to provide training for our staff
[SID_595] We will continue to make use of third-party ethical labour audits
[SID_595] This will apply to any new development on site during the year and a proportion of refurbishment projects with a value in excess of 1.0 million
[SID_595] We will launch our response protocol on live sites and communicate with our contractors on how they should use it
[SID_595] We will continue to review and respond to potential risks in the material supply chain where materials and products are sourced from outside of the UK and EU
[SID_595] DUE DILIGENCE PROCESSES Modern slavery is a crime and a violation of fundamental human rights
[SID_595] It takes various forms such as servitude, forced and compulsory labour, slavery and human trafficking, all of which have in common the deprivation of a persons liberty by another in order to exploit them for personal or commercial gain
[SID_595] PHP expects all of its suppliers, contractors and service providers to act ethically, with integrity and to have in place effective systems and controls to combat modern slavery anywhere in their own business or in any of their supply chains
[SID_595] We have implemented the following safeguards: Due diligence: Before a new supplier, contractor or service provider is approved, appropriate due diligence on the supplier will be carried out
[SID_595] We require our contractors to be accredited by the SafeContractor Evaluation Scheme (www.safecontractor.com) and be listed as an accredited member on the SafeContractor database
[SID_595] As part of the process, the suppliers policies will be reviewed or they will be required to adhere to our policy if they do not have their
[SID_595] PHP plc Modern Slavery Statement 2024 own policy in this area
[SID_595] New suppliers will only be approved once they have completed this due diligence process
[SID_595] Policies: As referenced above, PHP has put in place an Anti-Slavery and Human Trafficking Policy
[SID_595] The policies set out PHPs expectations of its suppliers, including in relation to anti- slavery and human trafficking
[SID_595] suppliers are expected to adhere to these policies to reduce the risk of slavery and human trafficking occurring in our supply chains
[SID_595] Contractual measures: Where we identify risks in our supply chain, PHP will endeavour, to include contractual commitments in its agreements with contractors and suppliers to ensure they and any sub-contractors or sub-suppliers comply with anti-slavery and human trafficking laws, where these are not already in place
[SID_595] We will also reserve the right to audit compliance wherever possible
[SID_595] Audit: We carry out audits, commissioned via independent third-parties, of live construction sites to identify any issues relating to labour and employment practices
[SID_595] Where serious issues are identified or where we identify issues of concern, we may conduct follow up audits of suppliers business (including their policies, procedures and controls in place in relation to labour and employment)
[SID_595] Our current policy and commitment are to audit all new development projects once they are on site and a proportion of refurbishment projects with a value of 1.0 million or more
[SID_595] Breaches: PHP will view any breaches by a supplier of the PHP policy/code or the Suppliers contractual commitments (as applicable) very seriously
[SID_595] Were we to identify a breach of our supply chain policies or protocols, we would undertake an investigation into the circumstances, including root cause analysis
[SID_595] The circumstances of the breach, the results of the investigation and any process improvements and enhancements implemented as a result would be reported to the Executive Risk Committee and then to the Audit Committee and/or the ESG Committee as appropriate depending on the nature and severity of the breach
[SID_595] PHP will continue to proactively monitor the safeguards listed above, including reviewing its specific policies and processes to prevent human trafficking and consider implementation of further measures if and when required
[SID_595] Steven Owen, Chairman Primary Health Properties PLC Approved by the Board: 15th February 2024
[SID_598] Document name Modern Slavery Statement Policy Document type Policy Property of CloserStill Group Ltd Approved by Board of Directors Date reviewed 14-NOV-2024 Document version 001.002
[SID_598] Introduction
[SID_598] CloserStill Group Ltd is an international trade show, conference and events organiser, with operations in United Kingdom, USA, France, Germany, Spain and Singapore
[SID_598] Modern slavery is a crime and a violation of fundamental human rights
[SID_598] We are committed to acting ethically and with integrity in all our business dealings and relationships
[SID_598] CloserStill Group operates in many different countries, and there is a zero-tolerance approach to slavery or human trafficking
[SID_598] The principles of The Universal Declaration of Human Rights and the International Labour Organisations Declaration on Fundamental Principles and Rights at Work are supported by the CloserStill Group, both locally and Internationally
[SID_598] The CloserStill Group is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business
[SID_598] Whichever global location we run our events in we ensure we comply with the local laws and regulations
[SID_598] We realise that this is an ongoing and evolving obligation and we need to update our processes with regard to ongoing risk assessments in each global territory that we operate in
[SID_598] This statement is in accordance with section (54)1 of the Modern Slavery Act 2015 and constitutes CloserStill Groups slavery and human trafficking statement for the financial year ending 31st December 2023
[SID_598] Organisational Structure
[SID_598] The Board of Directors headed by the Chairman and the Chief Executive Officer are based in the UK
[SID_598] As at 31 December 2023 there were 603 employees consisting of sales, marketing, operations and administration staff, based in the following countries: United Kingdom 435, Germany 25, Spain 21, France 2, Singapore 35, USA 83 and Remote workers 2
[SID_598] The company is not involved in manufacturing and has strict employment policies and therefore we feel there is low risk amongst our direct employees
[SID_598] Supply Chain
[SID_598] The company organises trade shows and conferences in Healthcare and Technology market sectors
[SID_598] Our major suppliers are the venues where the events are held, the contractors who build exhibition stands, supply furniture, carpets, logistics and data registration services
[SID_598] Our major suppliers all have their own procedures and policies with regard to anti-slavery and anti- trafficking and we will continue to work with them to identify areas of risk further along the supply chain
[SID_598] We recognise that due diligence procedures with smaller suppliers needs to be reviewed
[SID_598] Customers
[SID_598] Our customers range from large pharmaceutical manufacturers to suppliers of kit for data centres and operators of care homes