The Howard de Walden Estate - Modern Slavery and Human Trafficking Statement

(For financial year end 31 March 2025)

Introduction from  Mark Kildea, Chief Executive Officer

It continues to be a priority for Howard de Walden Estates Limited to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain. This statement highlights the key activities we have undertaken during this financial year to combat modern slavery in our organisation and supply chain, and due regard has been had to the updated guidance for companies producing modern slavery statements as required by the Modern Slavery Act (MSA) 2015. In particular, this statement notes the increased expectations of transparency in the updated guidance and seeks to make as clear as possible the steps taken in the last financial year to isolate and counter any instances of modern slavery.

The United Kingdom Modern Slavery Act 2015 (“MSA”) requires certain companies to provide disclosure concerning their efforts, if any, to ensure there is no modern slavery or human trafficking in their organisation or supply chain. The following is the statutory statement by Howard de Walden Estates Limited (the "Company") made pursuant to Section 54 of the MSA (“S 54”) having been adopted by a meeting of the board of directors of the Howard de Walden Estate. The statement has also been approved by Howard de Walden Estates Holdings Limited, the 100% parent company of the Company.

While only the Company and Howard de Walden Estates Holdings Limited are required to make a disclosure under Section 54, the statement reflects the practices of the group and its subsidiaries (who are referred to collectively in this statement as the “Group”).

The Group adopts a zero-tolerance stance in relation to modern slavery. The Group has therefore adopted an anti-slavery policy to set out its values in relation to these issues. The intention is to create a clear declaration of principles which leaves no doubt as to our stance.

1. Organisation's structure, its business and supply chains

1.1 Description of organisation and group structure

The Howard de Walden Estate are the freehold owner of most of the buildings in 95 acres of Marylebone, central London, UK. It manages and leases properties across an area that extends from Marylebone High Street in the west to Portland Place in the east and from Wigmore Street in the south to Marylebone Road in the north.

We are a part of the Howard de Walden group, and our ultimate parent company is Howard de Walden Estates Holding Limited, who has its head office in London, UK. The Group includes Howard de Walden Estates Holding Limited, Howard de Walden Management Limited and its subsidiary companies who are identified in the group accounts, all of which operate in the UK . We have over 150 employees in the UK and have a global annual turnover of £165 million.

1.2 Organisation and supply chain structure

The Company has a wide range of suppliers. Prominent members of our supply chain include construction and building maintenance contractors. Our work places a heavy reliance on sub-contractors. We have four employed members of staff who deal with day-to-day maintenance tasks, and all other work on the buildings on the estate is performed by sub-contractors.

We provide our suppliers with a terms and conditions document which places an obligation on all suppliers to inter alia not engage with any activity that would constitute slavery, and to undertake reasonable due diligence on their own supply chains.

Additionally, employees of the company are provided with an Employee Handbook which contains an anti-slavery policy, and there is an expectation that employees will read, understand and apply the letter of that policy. In particular, that policy prescribes that the Company’s commitment to addressing the issue of modern slavery in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

The Company also deals with suppliers of business inputs such as physical office premises, information technology, professional service providers, advisors and specialist consultants. We note that whilst the previous guidance for companies producing modern slavery statements gave the term ‘supply chain’ its everyday meaning, the updated guidance explains that a supply chain includes physical assets and labour within all tiers of suppliers who contribute to a product or service.

That being so, our heavy reliance on sub-contractors means that our supply chain is as expansive as the supply chain of those sub-contractors. Due diligence is performed in relation to each of our sub-contractors. This includes sending them our Slavery and Human Trafficking Questionnaire, checking that health and safety policies are in place within each sub-contractor’s business, and ensuring that each sub-contractor agrees to the Company’s health and safety policy. In addition only those companies which pass the credit checks we performed are accepted as sub-contractors.

1.3 Supply chain understanding

We recognise that it is crucial for us as an organisation to have oversight of our supply chains so that we can understand the risks of modern slavery along the chain and take action to mitigate against those risks. An important factor in this process is our reliance on sub-contractors, who may not typically be required under the Modern Slavery Act 2015 to themselves put in a Modern Slavery Statement and accordingly may not have a clear mapping process in place for their own business. This does not stop us from asking for such information in our Slavery and Human Trafficking Questionnaire, which demonstrates that we are actively concerned with protecting against modern slavery.

1.4 Our supply chains

At present, as above, our understanding of the supply-chains which lead into our business is governed by our reliance on smaller sub-contractors who themselves have separate supply-chains. However, we ensure that 98% of the estate’s spend on suppliers are provided with our Slavery and Human Trafficking Questionnaire which addresses extensively issues including but not limited to anti-slavery policies, anti-slavery training, details of their direct suppliers pertinent to anti-slavery, and the extent to which foreign labour is used within their businesses.

We continue to communicate our commitment to addressing the issue of modern slavery to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.            

1.5 Modern slavery risk management governance

The Company recognises the continued need for vigilance in verification of members of its supply chain and will not hesitate to terminate its relationship with suppliers involved in human trafficking or modern slavery practices in any part of the world.

We ensure that we have identified named individuals and specific departments within the organisation to be responsible for our modern slavery risk management. Currently this role is undertaken by Mr Ian Sands, who is supported by Ms Ella Caldicott. The estate has ensured that training is given to all employees (as to which, see para 5 below), that the importance of modern slavery is properly communicated to all suppliers and sub-contractors, and that the Company adopts a vigilant approach to modern slavery.

1.6 Information gathering for the statement

The Company ensures it gathers information to respond to the MSA 2015 legislative requirements, including:

• Having processes in place to audit suppliers with regard to their practices on modern slavery and human trafficking, and has adopted provisions in its contracts with suppliers, which impose obligations on the supplier to cooperate with the Company’s audit practices.
• During the course of the financial year, sending over half of our suppliers our Slavery and Human Trafficking Questionnaire for completion which sought clarification/further information where necessary to be satisfied those suppliers did not pose a risk of slavery or trafficking.

1.7 Continuous improvement of operations and supply chain knowledge

Since making and publishing last year's statement, our organisation has aimed to improve our knowledge of operations and supply chains by producing and sending a more in-depth supplier questionnaire which sought information which has allowed us to improve our knowledge and understanding of additional supply chains.

In the coming year we will engage with existing suppliers, on a prioritised basis, to deepen our knowledge of their businesses, by improving our datasets to become more complete and comprehensive.  Such data includes ensuring statutory and contact information is improved and held in more suitable systems. These systems are widely available in the business and offer greater visibility of information, including controlled edit rights for staff, to ensure data is kept up to date in line with company policies and practices

2. Our policies on slavery and human trafficking

We have appropriate policies in place that underpin our commitment to aim to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. The Company is committed to the principle that those who work for it or for any contractor or supplier must have chosen their work freely and must be treated with dignity. The Company is also committed to paying its workers no less than the applicable living wage and ensuring that best practice is applied in respect to working conditions, workplace treatment and values of respect, diversity and non-discrimination.

2.1 Internal operating policies

Our slavery and human trafficking policies and due diligence process reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls aiming to ensure slavery and human trafficking is not taking place in our supply chains. We also have the following policies or documents in place, which wholly or partially pertain to modern slavery, which we continuously review and update and which form a part of our Employee Handbook:

• Anti-Slavery Policy
• Anti-corruption and bribery policy
• Disciplinary Procedure
• Health and Safety Policy
• Supplier Terms & Conditions including other contract documents (e.g., Supplier Code of Conduct and Sustainable Procurement Policy)

2.2 Communication and enforcement of policies

The Company mandates annual training for all staff members, delivered though iHASCO and is CPD accredited.  Completion of this course is compulsory, with staff required to pass the assessment; those who do not pass must retake the course until they achieve a passing grade. 

The Company recognise in particular, the risk of an occurrence of domestic servitude in properties owned or managed by us. To mitigate that risk, we provide enhanced training to staff on the issue of domestic servitude, to enable them to recognise and report any signs of this abhorrent and unacceptable practice.

The Company communicates our policies to suppliers by making documentation (Supplier Code of Conduct, Supplier Terms and Conditions) available to view on our corporate website (www.hdwe.co.uk), by referencing our Supplier Terms and Conditions in any work instructions generated from our Facilities Management system, and through reference in all contracts agreed with suppliers. 

The Company will take very seriously any actual or potential instance of suppliers or contractors being involved directly or indirectly in any form of modern slavery or human trafficking. The Companies response to any such discovery will depend upon a number of factors, including the number of victims, the gravity of the human rights violations, whether the supplier was involved directly or indirectly and whether or not the supplier has previously been involved in such conduct.

Where practicable, the Company will aim to work with the supplier and to provide it with assistance to adopt the Companies values and best practices.

As a general principle, the Company expects its suppliers to be well-informed as to the workings of their own supply chain and with the risk of slavery. It therefore takes seriously any instance of suppliers refusing to co-operate with its due diligence enquiries.

We are pleased to report that there were to our knowledge no violations of our policy during the 2024/2025 financial year.

Furthermore, the Company will not tolerate any of its officers or employees being involved in modern slavery or human trafficking. Any such employee will be subject to serious disciplinary actions in accordance with our employment manual and contract of employment.

2.3 Continuous improvement of policies

We are cognizant of the need to continuously review and update all our policies, particularly in light of the updated guidance for companies producing modern slavery statements as required by the MSA.

2.4 Grievance mechanisms

As part of our approach to prevent and mitigate the risk of slavery and human trafficking, the Company also has a whistleblowing policy through which employees can raise any suspicions they may have from time to time that modern slavery or human trafficking may be taking place in the Companies organisation or supply chain. In addition, individuals are able to contact Mr Ian Sands in relation to any issue pertaining to modern slavery and he will take the appropriate action.

Employees will be reassured that where suspicions are reported in good faith, they will receive no sanction if these ultimately turn out to be unfounded. In appropriate circumstances, the Company is willing to share slavery or trafficking related intelligence with law enforcement agencies regarding slavery or trafficking.

3. Identifying, assessing and managing risk of slavery and human trafficking

3.1 Risk assessment frequency

As reported in previous years, the Company continues to regard its procurement function and supply chain management as the principal areas of risk for the business. Our Slavery and Human Trafficking Questionnaire is the means by which we are able to assess ongoing likely risk.

3.2 Risk assessment governance

We ensure that we have identified named individuals and specific departments within the Company to be responsible for our modern slavery risk assessment. This task falls to the procurement team at the Company who, alongside Mr Ian Sands, undertake the due diligence for suppliers and subcontractors.

3.3 Identifying and assessing risks

As a property owner, the Company also needs to be alive to the risk of domestic servitude occurring within its properties.  The inclusion of clauses in leases requiring occupants to provide information to assist us in the detection of domestic servitude is an example of how we have set about this task.

The risk assessment process looks at sectors and industries and their relative slavery and trafficking exposure.  In this regard, the Company continues to identify as areas of elevated risk the supply of labour to contractors and sub-contractors within the construction industry.  We are aware of very serious occurrences of modern slavery and human trafficking abuses by employment agencies in the construction sector. For these reasons, suppliers in these categories are an important (but not the sole) area of our due diligence and audit efforts.

The Company also applies close scrutiny to those suppliers who are known to operate, directly or indirectly, in areas of the world where the Global Slavery Index (GSI) has found there to be a higher level of risk.  However, the exposure of our supply chain to areas of higher risk is very limited.

The Company also recognise that its supply management and human resource departments could also be at risk of exposure to slavery and trafficking (more specifically in terms of the discovery of victims) by virtue of the roles they carry out.

We also want to ensure that staff inspecting our leased properties recognise the potential indicators of domestic servitude. Whilst the Company staff recruitment and retention policies are legally robust, the Company recognise the need to be vigilant when using staff that have been engaged through agencies, which may not necessarily adopt the same values or care as the Company in their engagement or referral of staff.

As explained above, the Company also has a whistleblowing policy through which employees can raise any suspicions they may have from time to time.

As we have said in previous statements, the Company accepts that any risk assessment must be reviewed regularly to take account of any new information regarding modern slavery and human trafficking.

4. Monitoring and evaluation: our effectiveness in combating slavery and human trafficking

4.1 Use of data to monitor and evaluate

We use the data we receive from our Slavery and Human Trafficking Questionnaire to chart the effectiveness of our policies.

4.2 Utilising findings of monitoring and evaluation

We aim to use the findings from our monitoring and evaluation to influence our business practices as regards managing modern slavery risks.

5. Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.

5.1 Internal and external training

The Company mandates annual training for all staff members, delivered though iHASCO and is CPD accredited. Completion of this course is compulsory, with staff required to pass the assessment; those who do not pass must retake the course until they achieve a passing grade. 

The Company recognise in particular, the risk of an occurrence of domestic servitude in properties owned or managed by us. To mitigate that risk, we provide enhanced training to staff on the issue of domestic servitude, to enable them to recognise and report any signs of this abhorrent and unacceptable practice.

5.2 Training package development

The training is developed and delivered through iHASCO.

6. Future Steps

We will continue to assess the effectiveness of the measures we take and we will regularly review and refine our policies and procedures in relation to modern slavery.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending April 2025. It was approved by the board on 29^th September 2025.

Mark Kildea
Chief Executive Officer

On behalf of Howard de Walden Estates Holdings Limited and Howard de Walden Estates Limited

Date: 29 September 2025