Policy Statement

Antler Homes Plc commitment to respect in the workplace includes our full support for international efforts to promote ethical principles and practices related to the prevention of exploitation and abuse associated with modern slavery and human trafficking. Antler Homes Plc also expects commitment to these principles from all organisations with which Antler Homes Plc do business and will not support or work with others knowingly involved in slavery or human trafficking.

Antler Homes Plc 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.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels; directors; officers; agency workers; seconded workers; volunteers; agents; contractors; cleaning agencies; estate agents; corporate hospitality and suppliers.

Antler Homes Plc strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. Antler Homes Plc have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. Antler Homes Plc expect that our suppliers will hold their own suppliers to the same high standards and reserve the right to ask for their statement on the policy at regular intervals or if concerns are raised.

This policy will be updated and amended as necessary according to the law (Modern Slavery Act 2015).

Definition of Modern Slavery and Human Trafficking

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

Commitment

Antler Homes Plc are a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

• • • Antler Homes Plc have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
    • The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
    • Antler Homes Plc are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
    • Antler Homes Plc take a risk-based approach to our contracting processes and keep them under review. Antler Homes Plc assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach Antler Homes Plc will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.

Consistent with our risk-based approach Antler Homes Plc may require:

• • • employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct at any time
    • Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code
    • As part of our ongoing risk assessment and due diligence processes, Antler Homes Plc will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
    • Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

All employees will receive training on Anti-Slavery and human trafficking so that they know and understand what it is and what to look for in supply chains and all companies that they may have dealings with.