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Slavery and Human Trafficking Statement

INTRODUCTION

Broadway Malyan Holdings Limited and our subsidiary companies (together “Broadway Malyan”) are committed to improving practices and maintaining procedures and controls designed to ensure modern slavery or human trafficking is not taking place in our business or supply chain globally.

The renewal of this commitment is made with appreciation of the challenges and issues presented by both Brexit and the socio economic crisis caused by the current global health pandemic.

OUR ORGANISATION & SUPPLY CHAIN

Broadway Malyan is a global architecture, urbanism and design practice dedicated to creating cities, buildings and places that will provide a lasting legacy. Through a shared design ethos, we work together to create places with a strong sense of identity where people and communities want to live, learn, shop, work and relax.

We have approximately 500 employees worldwide and operates in the United Kingdom, Europe, Africa, the Middle East, Asia Pacific and the Americas. We have a global annual turnover of £47.1 Million.

Our supply chain primarily comprises of professional infrastructure consultancy providers, acting as sub-consultants. We also engage with suppliers of services for our offices, such as, facilities management, travel, insurance and office equipment.

We seek to partner with suppliers whose ethical principles align with our own. We expect our suppliers to operate fair and ethical workplaces, and share the commitment to ensuring that modern slavery and human trafficking is not taking place. We have updated our standard form contracts to add, where possible, a contractual provision ensuring compliance with the Modern Slavery Act 2015.

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

We currently have a number of policies which govern all aspects of modern slavery and human trafficking, these policies include the proper management of recruitment and cover the standards we expect of our employees, including our whistleblowing procedures. As part of our commitment to improvement we are developing a Practice Manual for Broadway Malyan, which will incorporate all of our group policies. We anticipate that this will be launched towards the end of 2021.

Our Practice Manual and associated Modern Slavery Act Policy will reflect our commitment to acting ethically and with integrity in all our business relationships. It will include steps to implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business and or our supply chains.

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

Our Risk, Audit & Legal Committee has oversight of identifying and mitigating any modern slavery risks within our supply chain and regularly engages with parts of the business which could be more at risk.

Our Risk, Audit & Legal Committee reports biannually to the Board of Directors.

We also have in place systems to:

  • Identify, assess and monitor potential risk areas in our supply chains.
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains;
  • Encourage voluntary reporting and to protect whistle blowers in accordance with our global whistleblowing policy and procedures. All employees can approach the Managing Director with any concerns.

RISK ASSESSMENT

Our work is predominantly with large developer clients to whom we provide architectural and design services and whose businesses are transparent, visible and subject to considerable stakeholder oversight. Those businesses themselves, like Broadway Malyan, will be required to produce a statement each year and be committed to tackling Modern Slavery and Human Trafficking.

It is possible that we may be novated to building contractors during the life cycle of a project, and in light of this the business is selective and careful with regards to which companies we agree to work with or be novated to, and the terms of such engagement.

We employ highly educated and highly skilled professionals. For other roles, we ensure compliance with market standards and national minimum wage obligations. We carry out due diligence on our third party suppliers and require them to comply with all applicable laws, statues and regulations.

We have identified that the key area of risk in our supply chain is the risk of third party Company’s employing low skilled migrant workers. We mitigate this risk by working only with reputable third parties, with whom we have built long term and strong relationships.

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING

In the three prior financial years and to date, we have not received any reported concerns relating to modern slavery or human trafficking.

We are however alive to and do not underestimate the further layer of complexity the pandemic has added, in terms of the efforts to combat modern slavery and exploitation. Both the pandemic and changes regarding freedom of movement may lead to higher levels of vulnerability, creating additional risks to the labour market and increased incidents of modern slavery on a global level.

TRAINING

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business staff receive our existing policy as part of their induction package. Additionally, in 2020, Broadway Malyan delivered business training across all of its studios. This incorporated specific training on the modern slavery and human trafficking policy.

Our next financial year ends on 30th April 2021. In advance of the year end this constitutes our slavery and human trafficking statement in respect of the 2020/2021 financial year.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and is made by the Ian Apsley, the Managing Director and a member of and authorised by the Board of Directors.