The Modern Slavery Act 2015 Slavery & Human Trafficking Policy

Introduction

This Policy Statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes as Arun Estate Agencies Ltd Slavery and Human Trafficking Policy/Statement for the current financial year ending 30th September 2017.

Organisation Structure and Business

Arun Estate Agencies Limited, is a large, independent estate agency in the South of England. Established since 1991 our wealth of experience and excellent range of supporting services include residential estate agency & lettings, the arrangement of mortgages & insurance products, land and new homes and conveyancing via third party providers to provide the complete property service. We have 115 estate agency branches operating under different trading brands; Ward & Partners, Cubitt & West, Douglas Allen, Pittis & Rooney & Co. Supporting services are provided by our trading brands; Mortgage Matters Direct and Home in One Financial Services Ltd.

Policy Statement - Our Ethos on Slavery and Human Trafficking

Arun Estate Agencies Limited is committed to combatting Slavery and Human Trafficking and takes responsibility for ensuring that its working practices comply with the Modern Slavery Act 2015. This Policy Statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure Slavery and Human Trafficking is not taking place anywhere within our Company or supply chain.

Due Diligence

After conducting an audit of our business and supply chain to assess areas of risk and likely exposure, the likelihood and severity of risk within the Estate Agency business has been found to be negligible. As part of the Company's due diligence process, we continually monitor and adopt effective systems to ensure that Arun Estate Agencies Ltd does not support or deal with any business or individual knowingly involved in Slavery and Human Trafficking.

Supply Chains

We operate a zero tolerance policy to Slavery and Human Trafficking. All Head Office and Regional Office Directors, Heads of Department and other staff responsible for procuring external goods and services, are dedicated to ensuring that suppliers and providers always adhere to our ethos and support our compliance to the Modern Slavery Act 2015.

All staff involved in the procurement of goods and services are required to establish that they are dealing with known and trusted supply chains and to discuss the potential risks relating to any new supply chains. All supply chains have been provided with a copy of this Policy and are required to confirm their compliance with our ethos.

Recruitment

Our stringent HR policies and recruitment practices ensure compliance with The Modern Slavery Act 2015 and all other relevant employment legislation. Auditing practices are in place for checking that all employees have the right to work in the UK. We are continually reviewing our recruitment methods throughout the business to ensure transparency. Training for those employees who are engaged in recruitment and in sourcing and managing a supply chain, ensures that Slavery and Human Trafficking are not taking place within the organisation or its supply chain.

Awareness

The Modern Slavery Act 2015 is unlikely to be relevant to the majority of our branch based staff as they are not involved in the procurement of goods or services. Regardless, this policy is available to access on our internal database, Omni.

The staff involved or likely to be involved in the procurement of goods and services have been specifically provided with a copy of the Policy and instructed to ensure that their suppliers have been notified and have confirmed their compliance.

Reporting

If an employee has any concerns regarding a likely risk of, or actual breach of our Policy or the Legislation, this must be raised with Loretta Strong, Compliance & Protocol Director on 01702 540802 or Jo Potter, HR Director on 01403 282472.

Reporting can also occur in accordance with the Grievance Policy in general or with the Whistleblowing section of the Grievance Policy in particular.

All staff involved in the procurement of goods and services must contact Loretta Strong, Compliance & Protocol Director if they have any concerns about Slavery or Human Trafficking or if they are aware of or suspect a breach of The Modern Slavery Act 2015.

Revised: 15th June 2017