Policy Statement for the Financial Year ending April 2025
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Kimmeridge Real Estate has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Introduction
Kimmeridge Real Estate Ltd is committed to continually reviewing and improving our practices to combat slavery and human trafficking. Modern slavery is a crime and a gross violation of fundamental human rights. It takes various forms, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.
We expect the same high standards from all of our contractors, suppliers and other business partners.
Organisational Structure and Supply Chains
Kimmeridge Real Estate Ltd is a collaborative UK company owned and operated by its Equity Partners. Founded in 2016, the company provides value-added, client-centric investment sales and leasing advice to owners and occupiers of office, industrial, leisure, multi-family and hospitality properties.
With our in-depth understanding of the market, Kimmeridge Real Estate Ltd advises private businesses and the public sector on the whole real estate lifecycle - offering clients a service that spans the entire property lifecycle from strategy and planning, through to delivery and management.
Kimmeridge Real Estate Ltd are headquartered in London and employ 20 staff.
Organisational Policies
As a responsible company, we strive to carry out business activities ethically and with integrity.
In relation to people management, the primary policies relating to ethical working are our code of conduct and supplier code of conduct. Anyone working for or on behalf of Kimmeridge Real Estate Ltd is expected to uphold the values of the company.
The key requirements of the codes in relation to people are:
- Counter-acting illegal employment;
- Respect for the fundamental human rights of employees; and
- The ability of anyone in our supply chain, at any point, to flag concerns regarding malpractice.
Assessing and Managing Risk
Modern slavery and human trafficking comprises a number of activities that are contrary to legal or moral conduct. We have reviewed our supply chain and established that any risks that could possibly arise would fall into two categories; Forced Labour, meaning work or service which people are forced to do against their will under threat of punishment; and debt bondage is where people borrow money they cannot repay and are required to work to pay off the debt, losing control over the conditions of both their employment and the debt. With this in mind, we have considered our supply chain and assessed the risks of finding modern slavery issues as being low, as we source from technical and professional service providers from within the UK, and mainly from the professional services sector.
Due Diligence
We pay all employees and on-site contractors at least the National Living Wage as defined by the Living Wage Foundation, a process that is reviewed on an annual basis. We have a range of policies, including our Equal opportunities Policy, Grievance Policy and Whistle Blowing Policy, available to all employees to access and use in the unlikely event that this becomes necessary. All employees and new starters are made aware of their rights and our obligations under the Act and the policies that relate to this.
Kimmeridge Real Estate Ltd operates a supplier policy and maintains a preferred supplier list. We engage directly or via reputable agencies with each of our suppliers and conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery and on site audits which include a review of working conditions. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contravenes nor conflicts with this policy.
In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:
1. They have taken steps to eradicate modern slavery within their business;
2. They hold their own suppliers to account over modern slavery;
3. They pay their employees at least the national minimum wage (or, as applicable, the national living wage) and ensure that they operate lawfully in each country in which they operate; and
4. They understand that we may terminate the contract at any time should any instances of modern slavery
To support effective assessment of our supply chain we have strengthened due diligence questions and requirements of our supplier vetting programme, to focus on fair employment and ethical practices, supported by a supplier code of conduct that we expect all suppliers to sign up to and comply with at all times in the course of their business dealings with us.
The supplier code of conduct includes a commitment from the supplier to permitting and co-operating with any audit requirement that arises during the course of the relationship.
Training
To ensure that our Partners and employees understand the risks of modern slavery and human trafficking in our supply chains and our business, we provide them with a copy of the Modern Slavery Policy on our cloud based document sharing platform and encourage them to report any concerns to their manager.
Management Commitment
Kimmeridge Real Estate Limited is committed to being a responsible business and this is demonstrated through our management team’s approach to all aspects of compliance and supporting a policy of continually reviewing our supply chain to identify and resolve any concerns that are found or arise.
This statement has been read by our Executive Board, who review and update it annually. It is signed on their behalf by:
Matthew McGrail
Partner, UK
May 2024
