Modern Slavery Statement

1. STATEMENT

1.1 William Davis Ltd is opposed to any form of forced labour including human trafficking and modern slavery and we recognise that we have a responsibility to take a robust approach to modern slavery and human trafficking and are committed to preventing it in our activities and that of our supply chains.

2. OUR BUSINESS

2.2 Our principal activities comprise acquiring developable land, obtaining planning, and building high¬ quality homes and communities. All of our operations and activities are UK based and we directly employ 400 employees.

3. ASSESSING THE RISK OF MODERN SLAVERY

3.1 We have carried out a risk assessment and we believe the business has a low overall risk of modern slavery in both our own operations and in our immediate supply chain. However, we are pro-active in ensuring we are making our workforce, sub-contractors and suppliers aware of the potential risks and would highlight the following:

• Directly Hired Employees:

We verify that all directly employed employees have the right to work in the UK before they start work with us and we make all employees aware of their working hours, working time regulations, holiday and leave entitlements and all other entitlements via the employee handbook. The company ensures that employees are rewarded fairly through a structured pay and benefits programme and in accordance with our equal opportunities policy and all of our direct employees are, as an absolute minimum, paid in accordance with the UK living wage.

All recruitment is centralised through the Head Office HR department, and where agencies are used to source candidates only selected reputable recruitment agencies are used.

• Suppliers

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. We operate a centralised procurement team that procures over 95% of housebuilding materials. Only sundry items with a unit value of less than £300 can be purchased outside of our procurement team. The vast majority of our procured materials and components are assembled and/or manufactured in the UK, with the balance procured from within Europe and the United States of America.

• Subcontractors

We have a diverse sub-contractor labour force including ground workers and housebuilding trades. We have completed our detailed risk assessment and information gathering from four higher risk sub-contractor trades (ground workers, security, landscaping and cleaning) about their employment and payment practices.

• Contingent Supplied Agency Workers

We require those supplying agency workers to prove that any operative has the right to work in the UK and that 100% of eligible staff on construction sites will have their CSCS cards or equivalent. We have also introduced a preferred suppliers list for our agency workers and require them to produce a written statement on their approach to preventing modern slavery and trafficking where they do not already have a company policy or statement.

4. ACTIONS TAKEN AND FURTHER STEPS

4.1 In 2019 we rolled out an awareness campaign on all sites to educate managers and employees on the significance of this issue and to highlight key signs and indicators of someone that may be a victim of modern slavery and how to report this. We are continuing this awareness programme through a series of training sessions for all employees that are directly involved in recruitment. This is in conjunction with ‘Stronger Together’ and is scheduled to be rolled in March 2020,

4.2 As stated previously we have introduced a preferred suppliers list for our agency workers and require them to produce a written statement on their approach to preventing modern slavery and trafficking where they do not already have a company policy or statement.

4.3 We are currently in the process of amending our standard purchase orders and standard subcontractor orders to ensure that it informs our suppliers and subcontractors of William Davis' commitment to preventing modern slavery and human trafficking.

4.4 We will continue to review our internal processes to identify what further steps can be taken to ensure that our obligations under the Act are met and that our Modern Slavery Policy is effectively implemented and complied with, so as to ensure that there is no slavery or human trafficking in any part of our business.

This is William Davis's Modern Slavery Statement for the period 1st June 2018 to 31st May 2019. It was approved by the Executive Management Team and is signed on its behalf by:

Mr G Higgins,

Managing Director

11th February 2020