MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR THE FINANCIAL YEAR ENDED 31 DECEMBER 2019
GLP is the leading global provider of modern logistics facilities and technology-led solutions, with US$64 billion in assets under management across its real estate and private equity segments. GLP carries on business in the UK through its UK affiliates, including GLP UK Management Limited (“GLP UK”). GLP UK is registered at Companies House with company registration number 11065864 and has its principal place of business in London, with affiliated offices across Europe.
This statement is made by GLP UK pursuant to section 54, Part 5 of the Modern Slavery Act 2015 ( the “Act”) and references to “we”, “us”, “our” or “the Company” are to GLP UK. It constitutes GLP UK’s slavery and human trafficking statement for the financial year ended 31 December 2019 and sets out the steps taken to ensure that slavery or human trafficking did not take place in our business and supply chain during this financial year.
Our business is within the real estate sector and our supply chain particularly for our development projects involves high volumes of construction. Our supply chain often involves several entities or projects performed by a prime contractor with a series of sub-contractors. We can only exercise control over our relationship with our contractual counterparty; those persons who contract with that counterparty will be performing services for the counterparty and not for other persons in the contractual chain.
The principal way in which we approach modern slavery risks in our supply chain is by way of the procedures as set out in our Construction Procurement Policy, our Third Party Diligence Policy and our Code of Business Conduct and Ethics (the “Code”) (together the “Policies”). The Policies include our seeking to conduct our business in a manner that is free from slavery and human trafficking.
We have a commitment to conduct our business and all our relationships based on integrity. This commitment is contained in our Code.
During this financial year we:
- Reviewed our Policies to to ensure our continued commitment to:
- implementing and enforcing effective systems and controls designed to eradicate modern slavery in our business and supply chains;
- being transparent in doing so through our disclosure obligations under the Act;
- Used risk assessments to ensure that;
- our efforts to prevent modern slavery are proportionate to the modern slavery risks we face, recognising that it can vary according to the jurisdictions, sectors, suppliers, the amount of control we have over our supply chain and other governance factors. Risk assessments are, therefore, integral to our attempts to eradicate modern slavery in our business and supply chains. In particular, we seek to ensure that modern slavery risk is managed as close to its source as possible, and by the management teams that have the most knowledge and expertise in the business or risk area. Modern slavery risks vary based on the characteristics of each business. The specific manner and methodologies by which these risks are addressed and mitigated vary based upon, among other things, the nature of the risks and of the assets and operations to which they apply, the geographic location of the assets, the economic, political and regulatory environment, and our assessment of the benefits to be derived from such mitigation strategies.
- we have identified that there is a risk of modern slavery and human trafficking within our construction supply chain, however given our commitment to our Policies, we consider the residual risk to be low and we continue to monitor the risks on an on-going basis.
While practices and procedures are not capable of identifying and preventing all modern slavery, our risk based approach is designed to enable efforts to be focussed where they are most needed and can most help eradicate modern slavery.
- Made available training to our staff on modern slavery risks;
- Operated a due diligence protocol that includes anti-slavery considerations embedded within our Third Party Due Diligence Policy, which applies when engaging or renewing third party suppliers; and
- Encouraged staff, our suppliers and business partners and anyone else to whom our Policies apply to report any concerns about modern slavery related to its businesses and direct supply chains in accordance with our Policies.
Our Policies demonstrate our commitment to implementing transitional steps to try to give effect to that of a full and detailed Modern Slavery and Human Trafficking Policy. As a business we continue to monitor the need for any further action.
Based on the above, we consider that our policies and procedures are transitioning towards a reasonable level of assurance of effectiveness in eradicating modern slavery and human trafficking in our business and supply chain.
Approved by the Board of Directors of GLP UK Management Limited.