Modern slavery

Organisation

This statement applies to Thakeham (referred to in this statement as ‘Thakeham’/’we’). The information included in the statement refers to the financial year April 2023 to March 2024.

We make this statement on behalf of all Thakeham entities and joint ventures, all of whom adopt its terms. The statement has been structured to align with good practice as outlined in Home Office guidance (Transparency in supply chains: a practical guide) and to set out measures in place within the Thakeham Group and its strategy for continuous review of its obligations under S54 of the Modern Slavery Act (2015).

Organisational structure and supply chains

Thakeham is a leading housebuilder in the south of England. We focus on finding suitable land on which to develop high quality homes whether for private use or in partnership with housing associations, councils and institutions. Our focus is on developing communities and creating amazing places to live. We operate in accordance with good industry practice, with a priority on safe working systems and high levels of customer service.

We are controlled by a board of directors that oversee all Thakeham entities. We employ approximately 26 people within the UK. Employees are all employed by one legal entity (Thakeham Homes Limited) but they work on projects across all of our entities. Our head office is in Billingshurst, West Sussex, where the majority of our employees are based.

At any one time, construction sites across the south of England will be run and controlled by Thakeham. These work locations are generally temporary in nature and dependent on the length of the construction project. The nature of our business requires that we work in conjunction with a range of suppliers, subcontractors, agencies and professionals. These organisations range in size from large sub-contractors to individual tradespeople.

In order to fulfil our activities, our main supply chains include those related to construction materials and products required to create a home. We use various suppliers in the United Kingdom, some of whom may purchase materials or goods from outside the United Kingdom. We also engage with subcontractor companies who carry out specific parcels of work on our sites using their own workforce. Labour supplied to Thakeham in pursuance of its contracts is carried out in the United Kingdom.

We understand that first-tier suppliers have further contractual relationships with lower tier suppliers.

Commitments on modern slavery and human trafficking

We consider that modern slavery encompasses:

human trafficking
forced work, through mental or physical threat
- being owned or controlled by an employer through mental or physical abuse or the threat of abuse
- being dehumanised, treated as a commodity or being bought or sold as property
- being physically constrained or to have restriction placed on freedom of movement.

We acknowledge our responsibilities in relation to tackling modern slavery and commit to complying with the provisions in the Modern Slavery Act 2015. We understand that this requires an ongoing review of both our internal practices in relation to its labour force and, additionally, our supply chains.

We do not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to us in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The organisation strictly adheres to the standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.

Assessing the risks of modern slavery

We deem the risk to those employed directly to be low for the following reasons:

All employees are on full written conditions of employment that are standardised and checked for compliance with the Act
All employees are paid at or above the National Minimum Wage
No casual labour is employed
Unpaid work experience is very limited in time and generally run through a school or college scheme
Internships/placement students are paid according to the National Minimum Wage
Employees have regular one to one meetings with their line manager which will include discussing any personal issues that may be affecting them

The HR team assesses the risk to those employed directly by Thakeham.

We consider our main exposure to the risk of slavery and human trafficking to exist where it is several steps removed from the procurement of materials through sub-contractors and where our first-tier suppliers have relationships with lower tier suppliers. Products may be created involving the provision of labour in a country where protection against breaches of human rights may be limited.

We also have a considerable number of workers on each site that are engaged through subcontract companies. Accordingly, there is a risk that this labour may have been trafficked from the UK or abroad.

Following the Government’s announcement to build 1 million new homes over this Parliament we could see an increased demand for labour in the construction industry and this situation could increase risk as more labour is sought to deliver this work..

In general, we consider our exposure to slavery/human trafficking to be relatively limited. we have taken steps to ensure that such practices do not take place in our business nor the business of any organisation that supplies goods and/or services to us.

Business and supply chain due diligence

We carry out due diligence processes in relation to ensuring that slavery and/or human trafficking does not take place in our organisation or supply chains, including conducting a review of the controls of our suppliers.

We have not, to our knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, Thakeham has taken the following steps to ensure that modern slavery is not taking place:

Working with a limited number of suppliers to build strong working relationships and a good understanding of their business.
Reviewed and amended standard terms of supply to incorporate the requirements of the Act and requirements of Thakeham.
Each order will remind them of their responsibilities to their supply chains and the implications to working with Thakeham. It will also provide for a reporting structure for any infringement or potential infringement.
Thakeham has an onboarding process for suppliers, which includes obtaining copies of our suppliers’ statements on slavery and human trafficking, which will be taken as evidence that the organisation concerned is starting to address this important issue.
We have shared our Modern Slavery Statement internally to all employees with some additional notes of what they should be aware of/looking out for.
We have displayed posters at all sites alerting people to the Modern Slavery Act, signs to spot potential victims and details of who to contact if they have a concern.
We have deployed specific modern slavery training for all site management and the commercial and procurement teams and all new joiners are required to complete training on the requirements of the Modern Slavery Act, what they should be looking out for and how to deal with any issues arising.
We have sent recent reminders out to the Construction team in relation to what to look out for.
Our Modern Slavery training is currently 98.4% complete with regular reminders sent out
We have included a slide on Modern Slavery in all of our site inductions and there is a specific section covering it in our trade supervisor training
We have sourced updated Modern Slavery statements from all of our on site temporary labour agencies detailing their approach and compliance with the Act

Effectiveness of our approach and the coming year

We have set the following methods to measure the effectiveness in ensuring modern slavery is not taking place in the organisation or its supply chains and to cover its commitments for the next 12 months.

Record and investigate any risks or reports of modern slavery that the business is alerted to
When updating policies considering if the Act needs to be referenced directly
Redistribute up to date Modern Slavery posters to be displayed at all sites
We will be carrying out a review of our top subcontractors by invoice value on all aspects of social value and Modern Slavery
Provide specific Modern Slavery training to all new site management, commercial and procurement teams
Share Modern Slavery resources such as toolbox talks etc. from ‘Stronger Together’ with our supply chain to facilitate further learning for their organisations
Source and review referesher training to be rolled out to the construction, procurement and commercial teams
Directors ensure they are vigilant for any signs of modern slavery during their monthly visits to construction sites. They are trained to recognise and address any potential issues promptly, maintaining the highest standards of ethical conduct and compliance with the company’s zero-tolerance policy towards modern slavery.The PQQ process will be further developed during the year with conversion to a fully electronic format that will allow for periodic data checks in the future.

Thakeham has not been required to investigate any issues relating to breaches of the Modern Slavery Act in the past 12 months.

Policies & documents

We have a whistleblowing policy that is available for all employees if they are unable to raise their concern directly with the appropriate Director.

Slavery Compliance Officer

Our HR Director is the company Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to Thakeham’s obligations.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Rob Boughton
Chief Executive Officer
Date: August 2024