Modern Slavery and Human Trafficking Statement
This statement is made in accordance with Section 54 of the Modern Slavery Act 2015 (the Act) for the financial year ended 31 December 2024.
It sets out the steps that Newcombe Residential Limited has taken to ensure that slavery and human trafficking is not taking place in any parts of our business or supply chains.
We are committed to acting ethically and with integrity in our business dealings and relationships, and to maintaining systems and controls designed to ensure modern slavery and human trafficking are not taking place in our business or across our supply chain.
Our Business
Newcombe Residential Limited provides estate agency and property services in the UK to include residential sales and lettings.
Relevant Policies
To reinforce our commitment to combating slavery and trafficking, we have implemented the following policies, which set out our zero-tolerance approach to modern slavery, both within our own operations and our supply chain:
- Our Sustainable Procurement Policy is designed to manage modern slavery and human trafficking issues. It sets out our position of zero tolerance of modern slavery and human trafficking in any form in our business and supply chains.
- Our Supplier Code of Conduct sets out our expectations of suppliers and others we conduct business with and their supply chain. We require all of our suppliers to operate in accordance with that Code.
- Our Whistleblowing Policy provides a mechanism for our employees and others working in our supply chain to report suspected breaches of our policies.
Supply Chain Risk
Newcombe Residential work with a supply chain for services, goods and work. Our supply chain consists of UK based professional services companies and other UK based providers such as IT and utilities providers and business service providers, which we have assessed as low risk for modern slavery and human trafficking.
A risk-based approach has been adopted to review suppliers. Where suppliers are required to make their own statements in accordance with the Act, we monitor the content of the statements published. In addition, under this risk-based approach, we seek further assurance that suppliers are adhering to our Policy standards.
Due Diligence Processes
As part of our initiative to identify and mitigate risk, we carry out appropriate due diligence when engaging and working with suppliers, whilst also ensuring that the work undertaken is proportionate to the services provided and the risk involved.
The due diligence undertaken as part of our annual Supplier Assessment for key suppliers includes Modern Slavery and Whistleblowing.
Training
To raise awareness of slavery and trafficking, and of our policies and procedures, Modern Slavery and Human Trafficking forms part of our mandatory annual training for all colleagues.
Measuring Effectiveness- Performance Indicators
In order to monitor the effectiveness of the steps we have taken to stop slavery and trafficking taking place in our business and supply chains, we will use the following performance indicators for the financial year ahead;
- Completion rates for the mandatory training completed by office-based staff. In 2024 completion rates were 100%.
- We monitor and categorise concerns reported to us. No concerns have been raised about our or colleagues.
- We will ensure that we continue to have terms and conditions in place with our supply chain that require MSA compliance as a key term.
Further Steps
We will continue to review our business and supply chains for the risks of slavery and human trafficking; review and revise as needed our Policies and procurement processes; enhance our performance indicators and disseminate relevant information as part of awareness training to relevant parts of our business.