GC CAPMDEN HILL LLP ("LLP")

Modern Slavery and Human Trafficking Statement for financial year ended December 2018

  1. Overview
    1. This statement is made under s54 Modern Slavery Act 2015 in respect of the financial year ended 31 December 2018. The LLP has a zero-tolerance approach towards any form of slavery, servitude, forced or bonded labour, or human trafficking (collectively referred to as 'modern slavery' in this statement).
    2. The LLP will not support any arrangement or relationship that is knowingly involved in modern slavery. We are committed to ensuring that there is no modern slavery in our business or in our supply chains, and to acting ethically and with integrity in all our relationships.
    3. The purpose of this statement is to set out the steps that the LLP takes to ensure that it and its supply chain (including contractors, suppliers, and business partners) do not engage in modern slavery.
    4. We consider the LLP's principal business of the sale and management of residential apartments to be very low risk. However, the development aspects of the Holland Park site were considered to be low to medium risk through the extended supply chain involved in the redevelopment of the site.
  2. Employees and members
    1. The LLP has a small number of employees all of whom are paid above the national minimum wage. Care is taken when recruiting and all employees are required to comply with all legal obligations and to comply with the LLP's Modern Slavery Policy.
    2. The LLP's membership comprises corporate bodies reflecting its joint venture nature. It has no individuals as members.
  3. Modern Slavery Policy
    1. The LLP has a Modern Slavery Policy. This covers, amongst other matters:
      • The LLP's approach to modern slavery;
      • Our commitment to transparency in the supply chain;
      • Compliance requirements;
      • Consequences for breach of the policy; and
      • Disclosure procedures and a commitment against retaliation/victimisation.
    2. A copy of the Modern Slavery Policy is available upon request
  4. Suppliers
    1. One of the members of the LLP is subject to a common ownership interest with the development manager, Native Land Limited, and which is the principal tier one supplier responsible for the arrangements made for the supply chain although many supply contracts are concluded direct between the supplier and the LLP. Native Land Limited has worked for many years with many of the main suppliers.
    2. The Holland Park Site is now post-completion. The main development contractor managing any defects during the warranty period, Brookfield Multiplex Construction Europe Limited, and the agents appointed to manage the estate, Knight Frank LLP, are both long established, reputable and premier in their respective sectors. Each have their own modern slavery statements setting out their approach and the safeguards they employ. Other contractors/suppliers during the course of the year were:
      • individual interior designers
      • a PR agency and a design agency
      • legal and audit providers.
      These were all assessed as very low risk, being professional services, and did not identify any risks of modern slavery. The terms of business with interior designers would nevertheless benefit from the inclusive of specific obligations in respect of modern slavery.
    3. Except as noted above in relation to interior designers, all contracts with suppliers require them to comply with all applicable laws, statutes, regulations and codes. This includes those relating to labour, anti-slavery and human trafficking laws, including but not limited to the Modern Slavery Act 2015.
    4. A breach of those contractual obligations by the supplier would be treated with the utmost gravity by the LLP and could lead to sanctions up to and including termination of the contractual relationship.

This Modern Slavery Statement was approved by the LLP's members on 2 March 2020.