Organisation

This statement applies to Thakeham Group (referred to in this statement as ‘Thakeham’).
The information included in the statement refers to the financial year April 2021 to March
2022.

Thakeham Group makes this statement on behalf of all Thakeham entities and joint
ventures, all of whom adopt its terms.

Organisational structure

Thakeham is controlled by a board of directors that oversee all Thakeham entities.
Employees are all employed by one legal entity but they work on projects across all
entities.

Thakeham has a head office in Billingshurst, West Sussex where the majority of the
employees are based, with a regional office in Wokingham, Berkshire and further satellite
offices being opened over a number of years in the South of England.

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.

Thakeham works within the construction industry and directly employs around 240 people in
the UK. Thakeham builds homes to be sold privately or on behalf of a housing association,
local authority or similar.

The nature of our business requires that we work in conjunction with a range of suppliers,
subcontractors, agencies, and professionals.

The labour supplied to Thakeham in pursuance of its operation is carried out in the United
Kingdom.

Definitions

Thakeham considers 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
of 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.

Commitment

Thakeham acknowledges its responsibilities in relation to tackling modern slavery and
commits to complying with the provisions in the Modern Slavery Act 2015. Thakeham
understands that this requires an ongoing review of both its internal practices in relation to its
labour force and, additionally, its supply chains.

Thakeham does 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 Thakeham 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
minimum standards required in relation to its responsibilities under relevant employment
legislation in the United Kingdom.

Supply chains

In order to fulfil its activities, the main supply chains of Thakeham include those related to
construction materials and products required to create a home. Thakeham uses various
suppliers in the United Kingdom and in some cases globally to provide the materials/good
they need.

Thakeham also engages with subcontractor companies who carry out specific parcels of
work on our sites using their own workforce.

Thakeham understands that the first tier suppliers have further contractual relationships with
lower tier suppliers.

Potential exposure

Thakeham deems the risk to those employed directly to be extremely 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 or internships are regulated through a standardised risk
assessment

• Employees have regular one to one meetings with their line manager which will include
discussing any personal issues that may be affecting them

Thakeham considers its 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.

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

In general, Thakeham considers its exposure to slavery/human trafficking to be relatively
limited, it has taken steps to ensure that such practices do not take place in its business nor
the business of any organisation that supplies goods and/or services to it.

Steps

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

Thakeham has not, to its 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 businessA review and amendment of 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.

• Seeking copies of our suppliers’ statements on slavery and human trafficking, which
will be taken as evidence that the organisation is starting to address this important
issue and that in the current year we can assume compliance with the Act.

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 Progressed with specific modern slavery
training for all site management and the commercial/procurement teams.

Effectiveness of our approach and the coming year

Thakeham has set the following methods to measure its 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

• Re distribute up to date Modern Slavery posters to be displayed at all sites

• Include a slide on Modern Slavery in our updated site inductions

• 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

• 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.

Policies & documents

Thakeham has 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

Thakeham’s 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

CEO

Date: October 2022