Modern Slavery Statement

Introduction

This policy sets out Inspired Villages’ commitment to removing, wherever it exists, slavery or human trafficking in our business and supply chains. Should our employees have any concerns regarding likely risk, or breach of this policy or regulations they should not hesitate to raise this with their line manager, who should escalate to the appropriate Director.

Organisational structure and supply chains

Inspired Villages builds retirement villages within the commercial construction sectors working with a wide range of suppliers involving significant transactions across the supply chain. Inspired Villages was established in 2017 with the mission to deliver healthy living and lifestyles to people looking for their last time buy. We aim to operate with complete transparency. 

Due Diligence Process

Inspired Villages undertakes due diligence on new suppliers, and regular reviews of existing suppliers. This process includes a Supplier Code of Conduct, which we required all supplier to adhere to and forms part of the tendering process new suppliers.  Each company will be required to demonstrate due diligence in their processes. Should it become necessary we will arrange unannounced audits. 

This process will also enable us to:

• Identify and assess potential risk within our supply chain

• Map the supply chain to assess particular product or geographical risks of modern slavery and human trafficking

• Mitigate and resolve any risk within our supply chain

• Identify any risks as high, medium or low and take appropriate action

• Create an annual risk profile for each supplier

• Monitor risk within our supply chain and conduct audits if necessary

• Take steps to ensure substandard suppliers implement appropriate action plans 

• Protect whistleblowers

• Check the ethical supplier database for suppliers’ labour standards, compliance in general, and modern slavery and human trafficking in particular

• Invoke appropriate sanctions against suppliers which could include termination of the business relationship 

Compliance with Processes, Values and Ethics

Inspired Villages will effectively manage its supply chain through the knowledge and expertise of people within the functions, namely Development, Construction, Finance, HR, Operations and Sales.

• Risk assessment:  Inspired Villages will have an organisational risk register where modern slavery and human trafficking will be a standing agenda item.

• Investigations/due diligence: Inspired Villages will not hesitate to undertake an investigation in relation to known or suspected instances of slavery and human trafficking.

• Training: Inspired Villages will provide appropriate training, and refresher training as appropriate to key managers

• Communications: Inspired Villages will communicate the policy via internal communications, including Inspired World platform.

Relevant policies:

• Inspired Villages has associated policies to minimise the risks of slavery and human trafficking in its business and supply chain;

• Whistleblowing policy: The whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can raise the matter with their line manager or directly with HR. 

• Employee Policies, procedures and guidelines: These guidance documents make clear to employees the actions and behaviour expected of them when representing the organisation. We strive to maintain the highest standards of employee conduct and ethical behaviours when managing our supply chain. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

• Supplier code of conduct: Inspired Villages is committed to its supply chain operating to the highest standards of ethics. This includes safe working conditions, treat workers with dignity. Act ethically and within the law.  However, serious violations of the code of conduct will lead to an investigation and possible termination of the business relationship.

• Recruitment/Agency workers policy: We use only specified, reputable employment agencies to source labour and always verify the practices of any new agency before accepting people from the agency.     ·

Performance indicators

Inspired Villages has reviewed its key performance indicators (KPIs) in light of the Modern Slavery Act 2015. As a result, the following KPIs will be measured:

• Review of our supply chain database, identifying any potential risks and value within the process.

• Developing a system for supply chain verification.

Training

Inspired Villages requires key people to have an awareness of the Modern Slavery Act 2015 and how to manage the supply chain through effective procurement.  Inspired Villages will provide training to manage the supply chain through effective procurement which will cover:    

• Inspired Villages’ procurement process; 

• Identifying unrealistically low prices;

• The use of labour, low wages or wages below the national minimum wage or the provision of products by an unrealistic deadline;

• How to escalate potential slavery or human trafficking issues to the relevant people within Inspired Villages;

• What external help is available, for example through the Modern Slavery Helpline. 

• This policy will be reviewed and updated annually.

Jamie Bunce
CEO

(Updated on 04/08/2019)